Case Summary (G.R. No. 169370)
Factual Background
In 1948, Emiliano Melgazo founded CPA to support his constituents. In 1968, he purchased property on behalf of this association, which later served as a wet market. After his death, Manuel Melgazo took over CPA's presidency, while Atwel and Pilpil held the positions of vice-president and treasurer, respectively. In 1997, a group of CPA members registered CPAI with the Securities and Exchange Commission (SEC), and the petitioners were excluded from this new entity.
Subsequently, CPAI opposed the petitioners' attempts to collect rents from the market, leading to a lawsuit filed in 2000 at the SEC. This case was transferred to the RTC under RA 8799, alleging that petitioners were unlawfully collecting rents without the proper authority.
Court's Findings and Ruling
The special commercial court ruled that the deed of sale registered was in the name of CPA, not Emiliano Melgazo, thus designating CPA, and inherently CPAI, as the rightful owner. The court then ordered petitioners to cease their rental collections and account for prior collections.
Appellate Proceedings
The petitioners challenged the jurisdiction of the special commercial court, asserting that they were not members of CPAI, and, therefore, the case could not involve an intra-corporate dispute. The Court of Appeals (CA) acknowledged the lack of intra-corporate jurisdiction but held that the petitioners were estopped from contesting the court's jurisdiction due to their active participation in proceedings.
Legal Principles Considered
The CA's interpretation rested on established legal principles, particularly referencing the ruling in Tijam v. Sibonghanoy, which addresses estoppel concerning jurisdiction. While legal precedent allows parties to challenge jurisdiction, if they have actively participated in the proceedings, estoppel may bar the objection.
Supreme Court's Assessment
Upon review, the Supreme Court disagreed with the application of estoppel. It confirmed that jurisdiction is a matter strictly conferred by law and cannot be established through party agreement or estoppel. The Court reiterated the criteria for an intra-corporate dispute, emphasizing that petitioners were never
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Case Overview
- This case involves a petition under Rule 45 of the Rules of Court, filed by petitioners Eustacio Atwel, Lucia Pilpil, and Manuel Melgazo against Concepcion Progressive Association, Inc. (CPAI).
- The petition challenges the decision of the Court of Appeals (CA), which declared the petitioners estopped from questioning the jurisdiction of Branch 8 of the Regional Trial Court (RTC) of Tacloban City as a special commercial court under Republic Act (RA) No. 8799.
Factual Background
- In 1948, Assemblyman Emiliano Melgazo founded the Concepcion Progressive Association (CPA) in Hilongos, Leyte, aimed at providing livelihood and income for his supporters.
- In 1968, Emiliano Melgazo, as CPA president, purchased a parcel of land that became a wet market and included various amusement facilities, generating rental income for CPA.
- After Emiliano Melgazo’s death, his son, Manuel Melgazo, succeeded him as CPA president, while Atwel and Pilpil were elected as vice-president and treasurer, respectively.
- In 1997, a faction within CPA registered as CPAI with the Securities and Exchange Commission (SEC), excluding the petitioners from membership or officer positions.
- CPAI filed a case in SEC, later transferred to RTC, alleging that it owned the property and that petitioners were improperly collecting rentals.
Proceedings in Court
- The special commerc