Title
Aldersgate College, Inc. vs. Gauuan
Case
G.R. No. 192951
Decision Date
Nov 14, 2012
Aldersgate College, Inc. challenged RTC's dismissal of an intra-corporate case based on a board resolution. SC ruled motions to dismiss prohibited, unresolved issues required trial.

Case Summary (G.R. No. 192951)

Factual Antecedents

In March 1991, the petitioners initiated a case involving several issues with the respondents. The SEC was later reorganized under Republic Act 8799, leading to the transfer of the case to the RTC. A Pre-Trial Order was subsequently issued outlining the pertinent issues, including the legitimacy of elected trustees, compliance with the By-Laws regarding financial transactions, and the accountabilities of certain trustees for corporate mismanagement. Despite several attempts by the respondents and respondents-intervenors to dismiss the case, the RTC denied these motions, emphasizing the necessity of presenting evidence for the issues at hand.

Court Proceedings

The respondents-intervenors filed a motion in February 2010 seeking dismissal based on the argument that the case was initiated without board authorization. The RTC ultimately granted this motion and dismissed the case on March 30, 2010, mainly relying on a December 14, 2009 resolution from the current Board of Trustees that recommended the dismissal. The petitioners subsequently filed a motion for reconsideration, which was denied by the RTC on June 29, 2010, leading to the appeal to the Supreme Court.

Issue Before the Court

The primary issue impinging on this case pertained to whether the RTC erred in dismissing the case based on the motion filed by the respondents-intervenors, given the nature of the intra-corporate dispute.

Court's Ruling

The Supreme Court ruled in favor of the petitioners, acknowledging the merits of their petition. The Court emphasized that the dismissal of the case was inappropriate, particularly given that the motion to dismiss was a prohibited pleading within the framework of intra-corporate controversies as stipulated in the Interim Rules of Procedure for Intra-Corporate Controversies. The decision stressed that the RTC should not have entertained or granted the motion, particularly in light of the complex issues

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