Case Summary (G.R. No. 203678)
Procedural Background
The case arose from a petition filed by CCI on April 16, 2012, seeking an injunction with damages against several individuals and entities, claiming misrepresentation of ownership over the condominium and violations of various building permits. Subsequent hearings were held, and the RTC issued an order to conduct inspections of the premises. However, on June 28, 2012, the RTC dismissed the petition for lack of jurisdiction, asserting that the case did not involve an intra-corporate dispute as required for the Special Commercial Court.
Basis for Dismissal
The RTC found that CCI had not established any intra-corporate relations with the respondents, including Baculio and New PPI Corporation, making the case ineligible for jurisdiction within the framework set for Special Commercial Courts. The denial highlighted that the dispute arose from conflicting claims over property ownership and regulatory safety concerns, not from internal corporate governance issues.
Petitioner’s Arguments
CCI contended that the dismissal was erroneous as it maintained that their petition for injunction with damages should be classified as an ordinary civil case, deserving the jurisdiction of the RTC regardless of its special designation. They argued that such courts retain general jurisdiction pertaining to civil matters, as stipulated by the Judiciary Reorganization Act and further delineated under RA 8799 that transferred certain SEC cases to regional trial courts.
Respondents’ Counterclaims
The respondents argued primarily that CCI failed to exhaust administrative remedies before resorting to judicial action regarding the building and occupancy permits. They claimed jurisdictional challenges based on the allegation that there was no intra-corporate relationship between the parties involved.
Jurisdictional Analysis
The Supreme Court, in its decision, clarified that actions for injunction and damages fall under the jurisdiction of the RTC. The case presented by CCI was determined to be an ordinary civil action based on the claims and reliefs sought from the court. It emphasized the importance of overall jurisdiction conformance over the subject matter at dispute rather than solely the
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Case Overview
- This case revolves around a petition for review on certiorari filed by Concorde Condominium, Inc. and unit owners against various respondents, including New PPI Corporation and its president Augusto H. Baculio, for the dismissal of their petition for injunction with damages.
- The petition stems from the Regional Trial Court (RTC) of Makati City, which dismissed Civil Case No. 12-309 for lack of jurisdiction.
Background of the Case
- On April 16, 2012, the petitioner filed a petition with the RTC of Makati City seeking an injunction against the respondents, primarily to prevent misrepresentation of property ownership and to stop actions that could lead to the demolition of the Concorde Condominium Building.
- The respondents included individuals and agencies associated with New PPI Corporation, the Asian Security and Investigation Agency, the Makati City Engineering Department, and the Bureau of Fire Protection.
Petitioner’s Allegations
- The petitioner alleged that respondents Baculio and New PPI Corporation falsely claimed ownership of the lots and the condominium building.
- They sought to prevent the Asian Security and Investigation Agency from deploying security guards around the property.
- The petition also called for the enjoinment of government officials from acting on misrepresented claims regarding building permits and safety issues.
RTC Proceedings
- The RTC held hearings to asse