Case Summary (G.R. No. 209370)
Factual Background
The case began from an Amended Complaint for Quo Warranto, Annulment of Board Decisions, Inspection of Records, Audit, Appointment of Receiver, and Damages, filed by the petitioners after alleged illegal acts by the board of directors of DAGUMA. The petitioners claimed to own 17% of total outstanding shares in DAGUMA but were countered by respondents who denied their standing, asserting that the petitioners were not stockholders of record. On January 16, 2006, the Regional Trial Court (RTC) issued a Writ of Preliminary Injunction (WPI) to prevent respondents from divesting petitioners' shares and conducting board meetings without notification.
Events Leading to the Motion for Document Production
Despite the WPI, the petitioners accused the respondents of executing a Share Purchase Agreement with San Miguel Energy Corporation (SMEnergy) that purportedly transferred all shares of DAGUMA, leading to a further conflict. Petitioners filed a Motion for Production of Documents on May 9, 2012, requesting the Share Purchase Agreement and related documents. The RTC ordered the respondents to comply, but this was met with resistance, culminating in a Motion to Vacate the Production Order which the RTC denied.
Court of Appeals Decisions
The respondents subsequently sought relief from the Court of Appeals (CA) to challenge the RTC's decisions regarding the production of documents. In response to their request for judicial courtesy while awaiting the CA's ruling on the prior case, the RTC issued an order on April 2, 2013, deferring the production of the SMEnergy documents. The CA upheld the RTC's decision, arguing that maintaining judicial courtesy was essential to prevent rendering moot the respondents' appeal pending before them.
Core Issues Presented
The central issue before the Supreme Court is whether the CA erred by sustaining the RTC’s Order, which deferred the production of SMEnergy documents until after a resolution was reached in CA-G.R. SP No. 127476. The petitioners contended that the deferment order should be lifted, thereby allowing them access to crucial documents related to their essential claims.
Court's Ruling
The Supreme Court concluded that the petition was moot and academic. This determination arose due to the RTC's ruling, rendered in a separate case, finding the petitioners to lack stockholder standing in DAGUMA. It was established that a case is deemed moot w
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Case Information
- Jurisdiction: Supreme Court of the Philippines
- Case Number: G.R. No. 213457
- Date: March 18, 2019
- Division: Second Division
- Petitioners: The Heirs of Edgardo Del Fonso, Beacon Equities, Inc., and Daguma Agro-Minerals, Inc.
- Respondents: Benjamin T. Guingona, Mamerto S. Bocanegra, Tomas J. Prudencio, Antonio Ilomin, Levitico Toquero, Arnold Manat, Generoso Senga, Christian M. Monsod, and Epifanio Sedigo, Jr.
- Nature of the Petition: Petition for Review on Certiorari under Rule 45
Background of the Case
- The petition arose from an Amended Complaint filed by Edgardo Del Fonso, now represented by his heirs, against several respondents who were directors and officers of DAGUMA Agro-Minerals, Inc.
- The petitioners, claiming to own 17% of the total outstanding shares of DAGUMA, sought a Quo Warranto, annulment of board decisions, inspection of records, an audit, appointment of a receiver, damages, as well as a Temporary Restraining Order (TRO) and a Writ of Preliminary Injunction (WPI).
- The core of the complaint included allegations of unlawful acts by the respondents as board members.
Procedural History
- On January 16, 2006, the RTC issued a WPI prohibiting the respondents from divesting shares or conducting meetings without notice to petitioners.
- Des