Facts:

• The case involves Stronghold Insurance Company, Inc. (petitioner) and respondents Tomas Cuenca, Marcelina Cuenca, Milagros Cuenca, Bramie T. Tayactac, and Manuel D. Marañon, Jr.
• On January 19, 1998, Marañon filed a complaint in the Regional Trial Court (RTC) of Parañaque City against the Cuencas for the collection of a sum of money and damages, including an application for a writ of preliminary attachment.
• The RTC granted the application on January 26, 1998, conditioned upon the posting of a bond of PHP 1,000,000.00.
• Marañon posted the bond issued by Stronghold Insurance on February 11, 1998, and the writ was issued two days later.
• The sheriff levied upon the equipment and other personal property of Arc Cuisine, Inc., found in its leased office.
• The Cuencas and Tayactac moved to dismiss and quash the writ, arguing that the action involved intra-corporate matters under the jurisdiction of the Securities and Exchange Commission (SEC) and that there was a pending action in the SEC and a criminal complaint in the Office of the City Prosecutor of Parañaque City.
• The RTC denied their motion, leading the Cuencas and Tayactac to file a certiorari petition with the Court of Appeals (CA), which annulled the RTC's orders and dismissed the amended complaint for lack of jurisdiction.
• The CA remanded the case to the RTC for hearing and resolution of the damages claim.
• The RTC held Marañon and Stronghold Insurance jointly and solidarily liable for damages.
• Stronghold Insurance appealed to the CA, which affirmed the RTC's decision.
• Stronghold Insurance then filed a petition for review on certiorari with the Supreme Court.

Issue:

• (Unlock)

Ruling:

1. No, the stockholders of a corporation cannot claim damages for the attachment of the corporation's assets.
2. Yes, the RTC and CA erred in holding Stronghold Insurance jointly and solidarily liable for damages beyond the amount of the bond....(Unlock)

Ratio:

• The Supreme Court emphasized that the personality of a corporation is distinct and separate from its stockholders.
• Therefore, the stockholders are not the real parties in interest to claim and recover compensation for damages arising from the wrongful attachment of the corporation's assets.
• Only the corporation itself has the right to claim such damages.
• The Court cited Section 2, Rule 3 of the Rules of Court, which requires that every action must be prosecuted or defen...continue reading