Case Digest (G.R. No. 154096) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Irene Marcos-Araneta, et al. v. Court of Appeals, et al. (G.R. No. 154096, August 22, 2008), petitioner Irene Marcos-Araneta alleged that her late uncle, Ambassador Roberto S. Benedicto, and his group had held in trust 65% of the shares of Far East Managers and Investors, Inc. (FEMII) and Universal Equity Corporation (UEC) since 1968 and 1972. When she and her original trustee-husband demanded reconveyance of the stockholdings, the Benedicto Group refused. In March 2000, Irene filed two suits before the Regional Trial Court (RTC), Branch 17 in Batac, Ilocos Norte—Civil Case Nos. 3341-17 (UEC shares) and 3342-17 (FEMII shares)—for conveyance of shares, accounting, and receivership, and sought a temporary restraining order. Defendant Francisca Benedicto-Paulino moved to dismiss No. 3341-17; the estate of Ambassador Benedicto (represented by his wife, Julita C. Benedicto, and daughter Francisca) likewise moved to dismiss No. 3342-17, asserting among others that venue was imprope Case Digest (G.R. No. 154096) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Organization and trust arrangement
- In 1968 and 1972, Ambassador Roberto S. Benedicto and associates formed Far East Managers and Investors, Inc. (FEMII) and Universal Equity Corporation (UEC).
- Irene Marcos-Araneta alleged that 65% of the shares in both corporations were held in trust for her benefit by Benedicto and his group.
- Initial RTC proceedings
- March 2000: Irene filed Civil Cases Nos. 3341-17 (UEC shares) and 3342-17 (FEMII shares) for conveyance of shares, accounting, receivership, and TRO.
- Defendants moved to dismiss on grounds of intra-corporate dispute jurisdiction, improper venue, and failure to state a cause of action.
- Preliminary hearing: defendants presented affidavits to disprove Irene’s Batac residency; Irene offered a community tax certificate (CTC).
- June 29, 2000: RTC dismissed both complaints for real action classification and improper venue; declared other issues moot.
- Amended complaint and RTC orders
- July 17, 2000: Irene moved to admit an amended complaint, adding three Ilocos Norte residents as co-plaintiffs (trustees).
- October 9, 2000: RTC admitted the amended complaint under Rule 10, Sec. 2, citing plaintiff’s right to amend and cured venue defect.
- December 18, 2000 & March 15, 2001: RTC denied defendants’ motions to dismiss and reconsider, and directed them to answer.
- Court of Appeals proceedings
- April 2001: Defendants filed a Rule 65 petition (CA-G.R. SP No. 64246) seeking certiorari to nullify the RTC orders admitting and sustaining the amended complaint.
- CA required proof of Julita’s authorization for Francisca’s signature and thereafter issued TRO and preliminary injunction.
- October 17, 2001: CA set aside the assailed RTC orders as null and void and dismissed the amended complaints.
- June 20, 2002: CA denied petitioners’ motion for reconsideration.
- Petition for review
- Petitioners filed before the Supreme Court under Rule 45, challenging the CA’s decision and resolution.
- They raised five grounds: verification compliance, merits on certiorari, validity of amendment, waiver of venue objection, and Irene’s residency.
Issues:
- Verification and Certification
- Did the CA err in accepting Julita’s affidavit as compliance with verification and non-forum-shopping certification?
- Merits disposition under certiorari
- Did the CA exceed its Rule 65 jurisdiction by resolving factual trust issues?
- Admission of the amended complaint
- Was the RTC’s admission void because the original complaints had become final?
- Waiver of improper venue
- Did defendants waive venue objections by filing subsequent pleadings?
- Venue and residency
- Was Irene actually a resident of Batac, Ilocos Norte?
- Did adding co-plaintiffs (trustees) cure the improper venue?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)