Title
Philippine Overseas Telecommunications Corp. vs. Africa
Case
G.R. No. 184622
Decision Date
Jul 3, 2013
The Supreme Court affirmed the Sandiganbayan's jurisdiction and upheld a compromise agreement in an intra-corporate dispute regarding share ownership in multiple corporations, including POTC.
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Case Digest (G.R. No. 184622)

Facts:

  • The case involves consolidated petitions under G.R. Nos. 184622, 184712-14, 186066, and 186590.
  • The dispute is between Philippine Overseas Telecommunications Corporation (POTC), Philippine Communications Satellite Corporation (PHILCOMSAT), and Philcomsat Holdings Corporation (PHC).
  • Petitioners include POTC and PHILCOMSAT, represented by various individuals.
  • Respondents include Victor Africa, Erlinda I. Bildner, Sylvia K. Ilusorio, Honorio Poblador III, among others.
  • The conflict centers on 5,400 shares of POTC stock, contested by several families, including the Ilusorio, Nieto, Poblador, Africa, Benedicto, Ponce Enrile, and Elizalde families.
  • The shares were allegedly taken from Atty. Potenciano Ilusorio during the Marcos regime through intimidation and transferred to corporations linked to the Marcos family.
  • After the EDSA People Power Revolution in 1986, the Presidential Commission on Good Government (PCGG) was established to recover ill-gotten wealth, including these shares.
  • The PCGG took control of shares held by Independent Realty Corporation (IRC) and Mid-Pasig Land Development Corporation, associated with the Marcoses.
  • A compromise agreement in 1996 recognized Atty. Ilusorio's ownership of 673 shares, with the Republic retaining 4,727 shares, approved by the Sandiganbayan in 1998.
  • Ongoing disputes regarding control of POTC and PHILCOMSAT led to contested stockholder meetings and elections.
  • The RTC of Makati City (Branch 138) ruled on the validity of these elections, prompting the current petitions for review.

Issue:

  • (Unlock)

Ruling:

  • The Sandiganbayan's refusal to take cognizance of the injunction suit was proper as it was an intra-corporate dispute.
  • The RTC (Branch 138) had jurisdiction over the election contest.
  • The lack of a pre-trial conference was not fatal to the intra-corporate election contest.
  • The RTC retained jurisdiction over the case that was ripe for adjudication.
  • The ruling in G.R. Nos. 141796 and 141804 was properly applied to Civil Case No. 04-1049.
  • The prop...(Unlock)

Ratio:

  • The Court emphasized that the Sandiganbayan's jurisdiction is limited to cases involving the recovery of ill-gotten wealth, while intra-corporate disputes fall under the RTC's jurisdiction.
  • The RTC (Branch 138) was designated as a special commercial court and had the authority to resolve...continue reading

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