Title
Concorde Condominium, Inc. vs. Baculio
Case
G.R. No. 203678
Decision Date
Feb 17, 2016
CCI sought injunction against Baculio et al. over disputed ownership, demolition threats, and permit revocations. SC ruled RTC had jurisdiction; case remanded for trial.
misrepresentation of ownership
deployment of security guards
jurisdictional dispute
A

Case Summary (G.R. No. 203678)

Factual Background

Petitioner alleged that it is the duly constituted condominium corporation that owns the common areas comprising the lot on which the Concorde Condominium Building stands and an adjacent parking lot, and that those rights were affirmed by prior HLURB proceedings. Petitioner averred that respondent Augusto H. Baculio, acting for New PPI Corporation, falsely claimed ownership of the subject lots and of the building and had repeatedly communicated with government agencies and private entities asserting such ownership. Petitioner further alleged that respondents pressured public officials to inspect, revoke permits, and even to order demolition, and that a private security agency engaged by Baculio deployed guards within the building perimeter, thereby threatening the unit owners’ peaceful possession and enjoyment.

Petition Filed and Reliefs Sought

On April 16, 2012 petitioner filed a Petition for Injunction with Damages in the RTC of Makati City, docketed as Civil Case No. 12‑309, seeking a Temporary Restraining Order, Writ of Preliminary (Prohibitory) Injunction, and Writ of Preliminary Mandatory Injunction. Petitioner sought to enjoin respondents Baculio and New PPI Corporation from misrepresenting ownership and from pushing for demolition, to prevent the Asian Security and Investigation Agency from deploying guards on the premises, and to restrain the Building Official and fire authorities from acting upon Baculio’s letters. Petitioner also sought actual, moral and exemplary damages, attorney’s fees, litigation expenses and costs.

RTC Proceedings and Interim Order

At the April 24, 2012 hearing the RTC interrupted testimony and issued an interim Order directing the Makati City Fire Marshal, Supt. Ricardo C. Perdigon, and the Makati City Building Official to conduct inspections and to submit reports by the following day, and giving the condominium corporation four months from April 30, 2012 to remedy deficiencies if repair was feasible. The Order enjoined other parties from interfering with the unit owners and warned of contempt for obstruction. The continuation of testimony was set on September 17, 2012.

Motions to Re‑Raffle and to Dismiss

Respondents Baculio and New PPI Corporation moved to re‑raffle the case on April 25, 2012, contending the matter belonged to a regular branch and not to a Special Commercial Court. The RTC denied the re‑raffle for failure to comply with Sections 4 and 5 of Rule 15, Rules of Court. Thereafter respondents filed a Motion to Vacate Order and Motion to Dismiss, arguing that the petition involved matters beyond the jurisdiction of a Special Commercial Court and that petitioner had not exhausted administrative remedies required by the National Building Code (P.D. No. 1096, Section 307).

RTC Dismissal and Denial of Reconsideration

In an Order dated June 28, 2012 the RTC dismissed Civil Case No. 12‑309 for lack of jurisdiction, reasoning that the petition alleged no intra‑corporate controversy cognizable by the court sitting as a Special Commercial Court and noting admissions that respondents Baculio and New PPI Corporation were not owners of the property. The RTC therefore found it unnecessary to resolve other procedural and substantive defenses. Petitioner’s motion for reconsideration was denied for lack of merit in a subsequent resolution.

Issue Presented to the Supreme Court

Petitioner presented a single issue for review: whether the RTC committed a manifest error of law and acted contrary to law and jurisprudence in dismissing the petition for lack of jurisdiction. The petition contended that the action for injunction with damages is an ordinary civil case within the RTC’s jurisdiction; that its erroneous assignment to Branch 149, a designated Special Commercial Court, did not divest that branch of its general jurisdiction; and that the petition should have been re‑raffled rather than dismissed.

Parties’ Contentions on Appeal

Petitioner argued that designation of Branch 149 as a Special Commercial Court did not deprive it of its character as a court of general jurisdiction under Batas Pambansa Blg. 129, and that re‑raffling procedures should have been employed when the court perceived the case to be an ordinary civil action. The Office of the Solicitor General, representing the public respondents, urged dismissal for failure to exhaust administrative remedies under the National Building Code and for failure to implead indispensable parties such as the DPWH Secretary. Respondents Baculio and New PPI Corporation asserted defects in verification, lack of exhaustion of administrative remedies, and public‑safety concerns; Asian Security and Investigation Agency maintained the matter was moot insofar as it had withdrawn its guards. The Makati Building Official likewise invoked non‑exhaustion of administrative remedies and factual violations of the National Building Code.

Legal Framework on Jurisdiction

The Supreme Court restated the established rule that subject‑matter jurisdiction is conferred by law and determined by the allegations in the complaint. The Court observed that actions for injunction and damages fall within the RTC’s original jurisdiction under Section 19 of Batas Pambansa Blg. 129, which grants the RTC power over civil actions incapable of pecuniary estimation and matters not within the exclusive jurisdiction of another tribunal. The Court reviewed P.D. No. 902‑A, which empowered the SEC with original and exclusive jurisdiction over intra‑corporate controversies and to issue injunctions, and noted that Congress transferred those intra‑corporate case categories to the courts by R.A. No. 8799, Section 5.2, while reserving to the Supreme Court the authority to designate which RTC branches would exercise jurisdiction over such cases.

Precedents on Special Commercial Courts and Jurisdiction

The Court surveyed its precedents, including GD Express Worldwide N. V. v. Court of Appeals and Manuel Luis C. Gonzales v. GJH Land, Inc., holding that branches designated as Special Commercial Courts remain courts of general jurisdiction and that the assignment to handle intra‑corporate disputes is procedural rather than jurisdictional. The Court explained that designation of a branch as a Special Commercial Court streamlines workload but does not diminish statutory jurisdiction conferred by BP 129 upon the RTC as a whole.

Supreme Court’s Analysis of the Petition’s Allegations

Applying the governing rule that jurisdiction is determined by the complaint’s allegations, the Court examined petitioner’s petition and found it pleaded an ordinary action for injunction with damages. The petition sought to enjoin third parties and public officials from acting on alleged misrepresentations of ownersh

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