Case Summary (G.R. No. 163511)
Background of the Case
The corporate bylaws of RPIC required an annual stockholders’ meeting on the first Friday of May. Lee Hiong Wee and his family had maintained control of RPIC since its incorporation on November 15, 1990. However, in July 2003, the Dee Ping group, dissatisfied with the Lee Hiong group’s management, petitioned the Securities and Exchange Commission (SEC) for a stockholders' meeting, which had not been conducted as required. The SEC agreed, leading to a meeting on October 9, 2003, resulting in changes to the board of directors.
Initial Court Proceedings
Following the October 9 meeting where a new board was elected, the Lee Hiong group filed a complaint in the Regional Trial Court (RTC) of Imus, Cavite, aimed at nullifying the results of this meeting. A temporary restraining order (TRO) was granted to prevent the Dee Ping group from asserting their newly claimed roles in management. This TRO initiated further legal actions, leading to a sequence of petitions and rulings contesting the management authority within RPIC.
Appellate Court Engagement
The Dee Ping group filed a petition for certiorari with the Court of Appeals (CA) successfully contesting the TRO issued by Judge Quisumbing, which effectively raised disputes about the jurisdiction and authority of the various overseeing judges and divisions of the CA. A new judge, Judge Mangrobang, was assigned to the case, and he issued a writ of preliminary mandatory injunction essentially restoring the Lee Hiong group to operational control.
Court of Appeals Decision
Subsequently, the CA issued a decision nullifying the writ of preliminary mandatory injunction, finding it issued in grave abuse of discretion and ordering the cessation of its enforcement. The CA indicated that the RTC should proceed expeditiously with the ongoing case, citing relevant legal frameworks regarding intra-corporate controversies. The core findings were that the conflicts between the groups represented distinct legal issues, thus validating the CA's decision to treat each petition as separate.
Petitioner’s Arguments
Lee Hiong Wee challenged the CA's decision, alleging due process violations, undue haste in the CA's actions, mootness relating to the TRO issued after the fact, and improper jurisdiction regarding the handling of the case by the CA’s Second Division amid ongoing proceedings in the First Division. The petitioner claimed that the CA's issuance of the TRO violated principles prohibiting forum shopping due to the similar nature of the disputes.
Court’s Resolution
The Supreme Court upheld the CA's decision, asserting that the issues raised were chiefly factual rather than purely legal; thus, they fell outside the scope of a Rule 45 appeal. The Court clarified that the issuance of the TRO was not without due process and reaffirmed judicial discretion in handling intra-corporate disputes
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Case Overview
- This case arises from a petition for review under Rule 45 of the Rules of Court, filed by petitioner Lee Hiong Wee against respondents Dee Ping Wee and Marina U. Tan.
- The case centers on a corporate dispute regarding the control and management of Rico Philippines Industrial Corporation (RPIC), a company involved in the seaweeds export business.
- The Court of Appeals (CA) rendered a decision on May 14, 2004, which declared null and void an order from the Regional Trial Court (RTC) of Imus, Cavite.
Background Facts
- The corporate bylaws of RPIC stipulate that an annual stockholders' meeting is to be held on the first Friday of May each year.
- Since its incorporation on November 15, 1990, the Lee Hiong group, led by Lee Hiong Wee and family members, managed RPIC.
- In July 2003, a faction led by Mario T. Tan and Dee Ping Wee filed a petition with the Securities and Exchange Commission (SEC), requesting a stockholders' meeting due to the lack of such a meeting in violation of corporate bylaws.
- The SEC approved the petition, leading to a stockholders' meeting on October 9, 2003, where a new board of directors was elected, largely representing the Dee Ping group.
Legal Proceedings
- Following the stockholders' meeting, the Lee Hiong group filed a complaint (SEC Case No. 029-03) to nullify the SEC's order and the sub