G.R. No. 140557-58 - People vs. Herrera

Background of Parties and Property
Respondent Robert H. Cullen purchased Condominium Unit No. 1201 from Meridien Land Holding, Inc. (MLHI); the unit’s title was thereafter issued in Cullen’s name.
On September 19, 2002, petitioner Medical Plaza Makati Condominium Corporation (MPMCC) demanded payment of unpaid association dues and assessments amounting to ₱145,567.42, alleging the obligation was a carry-over from MLHI.

Factual and Procedural Antecedents
Cullen had served as MPMCC president for 2000–2001 and claimed timely payment of all dues; MLHI later certified that it had settled any obligation on the unit.
MPMCC nevertheless prevented Cullen from voting and running in the 2002 board election; Cullen sought but did not obtain explanation from MPMCC regarding the claimed delinquency.
Cullen filed a Complaint for Damages against MPMCC and MLHI, alleging malicious branding as a delinquent member, deprivation of corporate voting and electoral rights, mental anguish, moral and exemplary damages, and counsel’s fees.
MPMCC and MLHI moved to dismiss for lack of jurisdiction: MLHI invoked exclusive HLURB jurisdiction; MPMCC argued intra-corporate controversy, prematurity, mootness, and lack of cause of action.
On September 9, 2005, RTC Makati Branch 58 granted both motions and dismissed the complaint for lack of jurisdiction.
On July 10, 2007, the Court of Appeals reversed and remanded, treating the case as an ordinary civil action for damages; motions for reconsideration were denied on January 25, 2008.
MPMCC petitioned the Supreme Court for review on certiorari under Rule 45.

Did the Court of Appeals correctly classify the dispute as an ordinary action for damages cognizable by regular courts?
Did the Court of Appeals err in exercising jurisdiction over a controversy that is intra-corporate in nature, thus requiring a special commercial court?
Were the RTC and HLURB proper fora for a dispute involving the internal affairs of a condominium corporation?