Case Summary (G.R. No. 168696)
RTC’s Venue and Transfer Ruling
Citing Rule 66, Section 7, the trial court initially transferred the petition to the RTC in Naga City, the residence of several respondents. The Naga court refused receipt, asserting that improper venue is not grounds to transfer a quo warranto case administratively.
RTC Branch 58’s Remand Order
On July 13, 2005, RTC Branch 58 denied petitioners’ motions to dismiss for improper venue and lack of jurisdiction, concluding that intra-corporate controversies formerly under the SEC’s exclusive jurisdiction must be heard by “special courts” designated by the Supreme Court under A.M. No. 00-11-03-SC and its supplements. It remanded the case to RTC Branch 23 in Naga City as the designated special court for Camarines Sur.
Issues Brought to the Supreme Court
Petitioners invoked Rule 45 certiorari, challenging (1) RTC Branch 58’s authority to remand for venue and jurisdiction defects, and (2) applicability of Administrative Circular No. 8-01 (January 23, 2001) to a case filed in May 2005.
Interlocutory Nature and Remedy Misstep
The Court observed that the July 13, 2005 order was interlocutory—denying dismissal but not disposing of the petition on the merits—and thus not appealable under Rule 45. Nonetheless, due to escalating tensions and potential violence, the Supreme Court treated the petition as a certiorari special civil action to resolve the jurisdictional issue without delay.
Quo Warranto in Intra-Corporate Disputes
Under pre-RA 8799 jurisprudence, quo warranto against private corporate officers fell within SEC jurisdiction (P.D. 902-A) and did not invoke Rule 66. RA 8799’s Section 5.2 transferred these cases to RTCs, but Rule 66 remains limited to public office usurpation. The Interim Rules (A.M. No. 01-2-04-SC) now govern intra-corporate controversies, including officer elections and authority.
Venue under the Interim Rules
Section 5 of the Interim Rules mandates intra-corporate petitions be filed in the RTC having jurisdiction over the corporation’s principal office. St. John Hospital’s principal office is in Goa, Camarines Sur. The designated Special Commercial Courts for Camarines Sur under A.M. No. 00-11-03-SC
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Facts
- On May 16, 2005, respondents filed a verified petition for quo warranto with damages and injunctive relief against petitioners before RTC-Br. 58, San Jose, Camarines Sur.
- Respondents alleged that petitioners, also incorporators and stockholders of St. John Hospital, Inc., had forcibly usurped board powers with armed men since May 2005.
- Petitioners were charged with usurping corporate office; respondents sought to annul those acts and recover damages.
Procedural History
- May 24, 2005: RTC-Br. 58 ordered transfer of the case to RTC, Naga City, citing Section 7, Rule 66, 1997 Rules of Civil Procedure.
- The Executive Judge of RTC, Naga City refused to receive the case folder, ruling that improper venue alone did not authorize transfer of a quo warranto case.
- RTC-Br. 58 served summons on petitioners. Petitioners filed Answers (June 8, 2005 onward) raising affirmative defenses: improper venue, lack of jurisdiction, and wrong remedy of quo warranto.
- Parties submitted memoranda supporting their positions.
Assailed RTC Order (July 13, 2005)
- Noted that intra-corporate controversies were originally within exclusive SEC jurisdiction under PD 902-A, Section 5.
- Cited RA 8799 (Securities Regulation Code, July 19, 2000) transferring SEC’s jurisdiction over those cases to RTCs, with Supreme Court-designated branches.
- Recounted A.M. No. 00-11-03-SC (Dec. 15, 2000) and supplemental A.O. 8-01 (effective Mar. 1, 2001) directing transfer of SEC cases to designated branches (e.g., RTC-Br. 23, Naga City).
- Held Motion to Dismiss prohibited under Interim Rules for Intra-Corporate Controversies (A.M. No. 01-2-04-SC, Section 8); denied the motion.
- Ordered remand of quo warranto petition to RTC-Br. 23, Naga City (Special Commercial Court).
- Cancelled scheduled hearing on temporary restraining order and preliminary injunction.
- Deferred resolution of propriety of quo warranto remedy to the competent court.