Case Digest (G.R. No. 125221)
Facts:
Reynaldo M. Lozano v. Hon. Eliezer R. De Los Santos; and Antonio Anda, G.R. No. 125221, June 19, 1997, the Supreme Court Second Division, Puno, J., writing for the Court.
Petitioner Reynaldo M. Lozano (Lozano) filed Civil Case No. 1214 for damages on December 19, 1995 before the Municipal Circuit Trial Court (MCTC) of Mabalacat and Magalang, Pampanga against respondent Antonio Anda (Anda). Lozano alleged he was president of the Kapatirang Mabalacat-Angeles Jeepney Drivers' Association, Inc. (KAMAJDA) and Anda president of the Samahang Angeles-Mabalacat Jeepney Operators' and Drivers' Association, Inc. (SAMAJODA). At the request of the Sangguniang Bayan of Mabalacat the two agreed to consolidate into the Unified Mabalacat-Angeles Jeepney Operators' and Drivers' Association, Inc. (UMAJODA) and to elect one set of officers to collect dues; elections were held on October 29, 1995, Lozano claimed he won, and Anda protested, alleged fraud, refused to recognize the results and continued collecting dues. Lozano sought to enjoin Anda from collecting dues and demanded P25,000 in damages plus P500 attorney's fees.
Anda moved to dismiss for lack of jurisdiction, asserting the Securities and Exchange Commission (SEC) had original and exclusive jurisdiction; the MCTC denied the motion on February 9, 1996 and denied reconsideration on March 8, 1996. Anda then filed a petition for certiorari before the Regional Trial Court (RTC), Branch 58, Angeles City (Civil Case No. 8237). The RTC granted the petition, found the dispute to be intracorporate and therefore within the SEC's jurisdiction, and ordered the MCTC to dismiss Civil Case No. 1214; it denied reconsideration on May 31, 1996.
Lozano petitioned the Supreme Court by a petition for certiorari seeking to annul and set aside the RTC decisions, arguing that the RTC acted with grave abuse of discretion in concluding that the SEC had jurisdiction over a dispute arising between heads of two separa...(Subscriber-Only)
Issues:
- Did the Regional Trial Court commit grave abuse of discretion amounting to lack or excess of jurisdiction in ordering dismissal of Civil Case No. 1214 and holding that the SEC had jurisdiction?
- Does the Securities and Exchange Commission have original and exclusive jurisdiction over the dispute between petitioners who were officers of two separate associations whose proposed consolidation had not been approved and certified by the SEC?
- Can the doctrine of corporation by estoppel operate to vest SEC jurisdiction in the absence of an app...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
- (Subscriber-Only)