Case Digest (G.R. No. 149357)
Facts:
Mobilia Products, Inc. v. Hajime Umezawa, G.R. Nos. 149357 and 149403, March 04, 2005, Supreme Court Second Division, Callejo, Sr., J., writing for the Court.Mobilia Products, Inc. (MPI) was a furniture manufacturer whose orders and marketing were handled by its Japanese parent, Mobilia Products Japan. Hajime Umezawa was sent by Mobilia Japan to the Philippines to serve as president and general manager of MPI and held one nominal share. In late January 1995, Umezawa organized, with family and former employees, Astem Philippines Corporation, a competing entity, and allegedly conspired to present Mobilia prototypes as Astem’s exhibits at the International Furniture Fair in Singapore.
Between February 8 and 19, 1995, several prototype furniture pieces were taken from MPI’s Mactan factory and stored at a third party’s warehouse; Umezawa allegedly supervised the removal and shipment. In March 1995, orders allegedly booked for Astem resulted in manufacture of 89 pieces using Mobilia materials, labor and facilities valued at P17,108,500. MPI’s board (three members) approved a resolution on May 2, 1995 authorizing the filing of criminal complaints.
A public prosecutor filed an Information for qualified theft (Crim. Case No. 013231-L) on May 15, 1995; subsequent Informations followed (Crim. Case Nos. 013423-L for theft of February 8 items, 013424-L for estafa re March manufacture). The trial court issued a preliminary attachment and denied Umezawa’s initial omnibus motions; it ordered reinvestigation of certain matters. Umezawa filed a petition with the Securities and Exchange Commission (SEC) on September 25, 1995 seeking nullification of the board resolution authorizing criminal complaints.
Following arraignment and renewed motions to quash, the Regional Trial Court (RTC) of Lapu‑Lapu City, in a Joint Order dated January 29, 1999, dismissed the criminal cases for lack of jurisdiction, holding the controversy intra‑corporate and within the SEC’s exclusive jurisdiction. MPI (through its private prosecutor) moved for reconsideration seeking reinstatement at least insofar as civil aspects were concerned; the trial court denied the motion on April 19, 1999. The Office of the Solicitor General (representing the People) filed a petition for certiorari and mandamus with the Court of Appeals (CA) on April 26, 1999; MPI was allowed to intervene.
The CA on September 2, 1999 granted the petition, nullified the RTC Joint Order and found the RTC had jurisdiction; on Umezawa’s motion for reconsideration the CA, by Resolution dated August 8, 2001, reversed itself and affirmed t...(Subscriber-Only)
Issues:
- Was the petition for certiorari filed by the People in the Court of Appeals time‑barred under Section 4, Rule 65 of the Rules of Court?
- Did the Regional Trial Court have jurisdiction over the criminal Informations for qualified theft and estafa, or were the matters within the exclusive jurisdiction of the SEC under P.D. No. 902‑A?
- Do the Informations charged against Hajime Umezawa sufficiently allege the essential el...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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