Case Digest (G.R. No. 165744) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Oscar C. Reyes v. Regional Trial Court of Makati, Branch 142, Zenith Insurance Corporation, and Rodrigo C. Reyes (G.R. No. 165744, August 11, 2008), petitioner Oscar and respondent Rodrigo are two of four children of the late spouses Pedro and Anastacia Reyes, who each held shares in Zenith Insurance Corporation. Pedro died in 1964 and his estate was partitioned in the 1970s; Anastacia died in 1993 without a similar settlement of her estate. As of June 30, 1990, Anastacia owned 136,598 shares, Oscar 8,715,637 shares, and Rodrigo 4,250 shares. On May 9, 2000, Zenith and Rodrigo filed with the SEC a derivative suit seeking an accounting of corporate assets and to recover shares allegedly “arbitrarily and fraudulently appropriated” by Oscar, including Anastacia’s shares. Oscar denied wrongdoing, claimed he bought the shares legitimately, and challenged the SEC’s jurisdiction as the dispute involved settlement of Anastacia’s estate. Upon effectivity of R.A. 8799, the SEC’s origin Case Digest (G.R. No. 165744) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Corporate Background
- Oscar C. Reyes and Rodrigo C. Reyes are two of four children of spouses Pedro and Anastacia Reyes.
- Zenith Insurance Corporation (“Zenith”) is a family-established domestic corporation; Pedro, Anastacia, Oscar, and Rodrigo each owned shares.
- Ancestral Estates and Shareholdings
- Pedro’s estate was judicially partitioned in the 1970s; Anastacia’s estate, including her 136,598 Zenith shares (as of June 30, 1990), remained unsettled.
- Oscar and Rodrigo individually held 8,715,637 and 4,250 shares, respectively, of Zenith stock.
- Proceedings Before SEC and RTC
- May 9, 2000: Zenith and Rodrigo filed a derivative and accounting suit against Oscar with the SEC (SEC Case No. 05-00-6615), alleging Oscar fraudulently appropriated spousal shares.
- Oscar answered, denied fraud, asserted he bought unissued shares, and challenged SEC jurisdiction as the dispute involved estate settlement.
- R.A. 8799 transferred SEC’s jurisdiction to designated RTC branches acting as special commercial courts; the suit was docketed as Civil Case No. 00-1553, RTC Makati Branch 142.
- Motion to Dismiss and Appeal
- October 22, 2002: Oscar moved to declare the complaint a nuisance/harassment suit under the Interim Rules of Procedure for Intra-Corporate Controversies and outside the special commercial court’s jurisdiction.
- November 29, 2002 RTC Order: Denied the motion in part, ruling the complaint contained two causes of action (derivative accounting and estate-share determination) and retained only the derivative suit.
- May 26, 2004: CA affirmed the RTC Order; Oscar’s motions for reconsideration were denied.
- Oscar filed a Rule 45 petition before the Supreme Court seeking annulment of the CA decision and dismissal of the complaint.
Issues:
- Jurisdiction
- Whether the RTC Makati Branch 142, acting as a special commercial court, had jurisdiction under P.D. 902-A (as amended by R.A. 8799) over Rodrigo’s complaint.
- Nature of the Complaint
- Whether the complaint was a bona fide derivative suit or merely a petition for settlement of Anastacia’s estate.
- Whether the complaint was a nuisance or harassment suit under the Interim Rules of Procedure for Intra-Corporate Controversies.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)