Case Summary (G.R. No. 125359)
Factual Background and Proceedings
On August 15, 1985, Aytona filed a petition with the Regional Trial Court of Quezon City (Branch 88) seeking a restraining order against the respondents. This petition was triggered by a preliminary injunction issued by the Superior Court of California, which restricted certain stockholders, including those of Sawyer-Adecor, from voting shares of NADECOR pending a determination of ownership over shares registered in Aguinaldo's name. Following the issuance of the restraining order by the Quezon City trial court on August 16, 1985, the stockholders’ meeting scheduled for August 19 was adjourned due to the ongoing legal proceedings.
Respondents’ Challenge
Despite service of the restraining order and summons to the respondents on August 21, 1985, including an attempt to serve Sawyer-Adecor through its President, Ms. Carol Garvic, the respondents filed a motion to dismiss Civil Case No. Q-45704 on September 3, 1985. They contested the court’s jurisdiction over the subject matter, the enforceability of the foreign order, and procedural issues related to Aytona's counsel. Sawyer-Adecor further contended that it was not engaged in business in the Philippines and therefore should not be subject to the court’s jurisdiction.
Trial Court’s Decision
On October 25, 1985, the trial court denied the motion to dismiss, asserting that jurisdiction over intra-corporate disputes, even those involving foreign entities, was within the Philippine courts’ purview. This led to the issuance of a writ of preliminary injunction on November 5, 1985, commanding the respondents not to vote on the shares in question.
Court of Appeals and Subsequent Rulings
Respondents subsequently sought relief from the Court of Appeals, which ultimately rendered a decision on November 28, 1986, annulling the trial court’s orders. They disagreed with the trial court’s reasoning concerning jurisdiction and the enforcement of foreign judgments, concluding that there was no foreign judgment requiring enforcement in the Philippines. The decision was reinforced when the motion for reconsideration by the petitioners was denied by the appellate court on January 23, 1987. The matters were consolidated for review.
Legal Principles and Conclusion
This case primarily examines whether the Regional Trial Court had jurisdiction to issue an injunction in light of the
...continue readingCase Syllabus (G.R. No. 125359)
Case Background
- The case arises from a dispute involving stockholders of Nationwide Development Corporation (NADECOR), a domestic corporation registered with the Securities and Exchange Commission (SEC).
- Petitioner Dominador R. Aytona, representing both himself and the estate of deceased stockholder Daniel R. Aguinaldo, filed a petition for a writ of injunction against several officers of NADECOR and Sawyer-Adecor International, Inc., an American corporation.
- This petition was motivated by an order of preliminary injunction issued by the Superior Court of California, which prohibited the voting of a significant number of NADECOR shares owned by Sawyer-Adecor pending the resolution of ownership issues concerning these shares.
Procedural History
- On August 15, 1985, Aytona filed a petition for a restraining order in the Regional Trial Court of Quezon City, which was subsequently docketed as Civil Case No. Q-45704.
- The trial court granted a restraining order on August 16, 1985, prohibiting certain parties from voting the Sawyer shares during the upcoming stockholders' meeting scheduled for August 19, 1985.
- The restraining order was served to the respondents on August 19, 1985, but was refused by Sawyer-Adecor's President, Ms. Carol Garvic, citing improper service.
- Following the