Case Digest (G.R. No. 202664)
Facts:
Manuel Luis C. Gonzales and Francis Martin D. Gonzales, G.R. No. 202664, November 20, 2015, the Supreme Court En Banc, Perlas-Bernabe, J., writing for the Court.Petitioners Manuel Luis C. Gonzales and Francis Martin D. Gonzales filed a complaint (docketed as Civil Case No. 11‑077) in the Regional Trial Court (RTC) of Muntinlupa City on or about August 2–4, 2011 against GJH Land, Inc. (formerly S.J. Land, Inc.), Chang Hwan Jang, Sang Rak Kim, Mariechu N. Yap, and Atty. Roberto P. Mallari II seeking injunctive relief to enjoin the sale of certain shares they claimed to have purchased and fully paid. The action raised intra‑corporate questions (status/ownership of stock subscriptions) although the caption identified it as a civil action for injunction with prayer for TRO, status quo and damages. The case was raffled to Branch 276 of the RTC of Muntinlupa City, a branch not designated as a Special Commercial Court.
Branch 276 issued a temporary restraining order on August 9, 2011 and a writ of preliminary injunction on August 24, 2011. After respondents answered, they moved to dismiss (arguing lack of subject‑matter jurisdiction because the dispute was intra‑corporate and thus cognizable by the Special Commercial Court designated in that station). In an Order dated April 17, 2012, Branch 276 granted the motion to dismiss, holding that intra‑corporate disputes fall within the exclusive jurisdiction of RTC branches specially designated as Special Commercial Courts (here, Branch 256), and therefore Branch 276 lacked jurisdiction. Petitioners moved for reconsideration; Branch 276 denied the motion on July 9, 2012, prompting this Rule 45 petition for review on certiorari to the Supreme Court.
The central procedural posture: the petition challenges Branch 276’s dism...(Pro-only)
Issues:
- Did RTC Branch 276 err in dismissing Civil Case No. 11‑077 for lack of jurisdiction over the subject matter?
- If the raffle of a commercial case filed in the official station of a designated Special Commercial Court is erroneous (i.e., wrong assignment to a regular branch), what is the proper procedural cour...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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