Case Digest (G.R. No. 202678)
Facts:
Ernestina A. Pagdanganan, Roderick Apacible Pagdanganan, Maria Rosario Lota, represented by her Attorney‑in‑Fact, Ernestina A. Pagdanganan, Ernest Jerome Pagdanganan, and Sandra Apacible Pagdanganan, as the heirs and substitutes of deceased Isauro J. Pagdanganan, Alfonso Ortigas Olondriz, and Citibank N.A. Hong Kong v. The Court of Appeals and Ma. Susana A.S. Madrigal, Ma. Ana A.S. Madrigal, Ma. Rosa A.S. Madrigal, Mathilda S. Olondriz, Vicente A.S. Madrigal, Rosemarie Opis‑Malasig, Maria Teresa S. Ubano, Eduardo E. Dela Cruz, and Guiller B. Asido, G.R. No. 202678, September 05, 2018, the Supreme Court Third Division, Leonen, J., writing for the Court.Solid Guaranty, Inc., a domestic insurance corporation, through minority stockholder Isauro J. Pagdanganan, filed an interpleader complaint in the Regional Trial Court (RTC) of Manila on November 23, 2007 (Civil Case No. 07‑118329) because of competing claims to shares of the late Antonio P. Madrigal between the Madrigals and Citibank N.A. Hongkong. While that case was pending, a Special Stockholders’ Meeting was held on November 26, 2007 at which new directors were elected; Solid Guaranty and Pagdanganan amended their interpleader complaint on December 17, 2007 to implead the newly elected directors and to seek nullification of the meeting and elections.
Respondent Maria Teresa S. Ubano, the newly elected corporate secretary, filed motions with the RTC in January and May–June 2008 to take custody of corporate records and to register stock transfers; the RTC granted relief in part and, on June 27, 2008, issued a Joint Order authorizing a stockholders’ meeting to avert prejudice to corporate operations. A Special Annual Stockholders’ Meeting was held on June 30, 2008 and new directors were elected.
On July 11, 2008, Solid Guaranty, Pagdanganan, Alfonso, and Citibank filed a petition for certiorari, prohibition, and mandamus with prayer for preliminary injunction before the Court of Appeals (CA) (CA‑G.R. SP No. 104291), alleging grave abuse by the RTC in allowing the June 30 meeting despite the pending interpleader suit and impleading the Madrigals, certain newly elected officers, and the presiding RTC judge. The parties filed numerous supplemental petitions, motions, comments and memoranda between 2008 and 2012; the CA repeatedly noted that the case could have been submitted for decision earlier but deferred action because of successive supplemental petitions and attendant pleadings.
The CA issued a resolution on October 6, 2010 expunging the Second and Third Supplemental Petitions and deeming the case submitted for decision; petitioners moved for reconsideration, and after substitution of Pagdanganan’s heirs (following his death on March 24, 2011) the CA again set comment periods. Petitioners later filed a Motion for Mediation (January 2012) and other motions. On December 14, 2012 the CA denied the Motion for Mediation and Motion for Reconsideration and reiterated that the petition was submitted for decision. The CA rendered a Decision dismissing the petition on February 8, 2013, and resolved the Motion for Reconsideration on March 10, 2014.
While these CA proceedings were pending, the heirs (and others) filed a Petition for Mandamus in the Supreme Court on August 2, 2012 seeking to compel the CA to resolve CA‑G.R. SP No. 104291, alleging inordinate delay...(Pro-only)
Issues:
- Is the Petition for Mandamus in the Supreme Court moot and academic in view of the Court of Appeals’ dispositions in CA‑G.R. SP No. 104291?
- Assuming the Court may still reach the substantive question, did the Court of Appeals commit inordinate delay in resolving CA‑G.R. SP No. 104291 in violation of petitioners’ right to sp...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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