G.R. No. 123910 - Unilongo vs. Court of Appeals

The dispute involves two contending groups—the Unilongo group (petitioners) and the DiAo group (private respondents)—asserting to be the rightful officers of the Sto. Niao de Cul de Sac Neighborhood Association, Inc. (SNSNAI) and the Sto. Niao de Cul de Sac Homeowners Association, Inc. (CDSHA).
SNSNAI was incorporated on 4 July 1989 by the Unilongo group as a non-stock corporation registered with the Securities and Exchange Commission (SEC).
No elections for a new Board of Trustees were held immediately after incorporation, leading to mounting grievances among the DiAo group.

On 29 April 1991, the Unilongo group amended the SNSNAI By-Laws, extending the term of the Board of Trustees from one year to two years.
Elections were held on 5 May 1991 in which the DiAo group emerged as the new Board of Trustees, thereby challenging the existing control.
In response to the electoral outcome, on 21 May 1991 the Unilongo group established CDSHA and registered it with the Home Insurance Guarantee Corporation (HIGC) in an apparent effort to perpetuate their control.
A subsequent complaint for injunction and damages was filed by CDSHA against the DiAo group (docketed in HIGC Case No. 155), while the DiAo group also pursued quo warranto relief to validate their election and oust the petitioners from corporate positions.
On 25 October 1992, further elections were conducted for SNSNAI with the DiAo group being re-elected, prompting additional motions including a request to annul these elections.

The Regional Trial Court of Makati (Branch 63) handled the initial quo warranto complaint filed by the DiAo group.
Petitioners filed an Answer with Counterclaim on 28 December 1992 and a Motion to Dismiss on 4 January 1993 asserting lack of jurisdiction over the case by the regular courts.
Despite the motion to dismiss centering on jurisdiction, the trial court clarified on 15 January 1993 that the motion pertained only to the individual petitioners, and the case proceeded to trial.
After further pleadings and evidentiary presentations, the counsel for one party was replaced and a subsequent manifestation reiterating the motion to dismiss was filed on 10 November 1994.
On 3 January 1995, the trial court denied the motion to dismiss, holding that despite the statutory provision in R.A. No. 580 and its amendments, it had jurisdiction to resolve the controversy under B.P. 129.
A motion for reconsideration was subsequently filed by petitioners on 12 February 1995, which was denied on 28 April 1995 for raising no new issues.
Petitioners then elevated the matter to the Court of Appeals through a petition for certiorari and prohibition, which was dismissed on 13 October 1995 and again through a motion for reconsideration on 2 January 1996.

Petitioners argued that disputes involving homeowners associations fall under the exclusive jurisdiction of the HIGC as provided by Executive Orders Nos. 90 and 535 amending R.A. No. 580.
The DiAo group contended that the Regional Trial Court properly assumed jurisdiction pursuant to Rule 66 of the Rules of Court and Section 21(1) of B.P. No. 129, which confers jurisdiction for quo warranto proceedings.
The controversy was framed as an intra-corporate dispute, central to determining which group was legally entitled to exercise corporate functions in administering the homeowners association.

Whether the dispute involving the rightful control of the homeowners associations is an intra-corporate controversy that falls exclusively within the jurisdiction of a specialized administrative agency (i.e., the SEC or HIGC) rather than the ordinary courts.

Whether the regular courts can exercise jurisdiction over quo warranto actions when the complaint involves corporate controversies, particularly in light of provisions in the Rules of Court and special laws such as Presidential Decree No. 902-A and the Corporation Code.

Whether, in view of Executive Orders No. 90 and 535, jurisdiction over disputes and controversies of homeowners associations has been transferred from the SEC to the HIGC, thereby precluding regular court intervention.

Whether the trial court abused its discretion by denying the motion to dismiss on the ground of lack of jurisdiction, considering that the issues raised were essentially intra-corporate and should be resolved by administrative bodies.