Title
Philippine Overseas Telecommunications Corp. vs. Africa
Case
G.R. No. 184622
Decision Date
Jul 3, 2013
A legal battle over control of sequestered telecom corporations (POTC, PHILCOMSAT, PHC) between the Ilusorio Group and PCGG, involving jurisdiction, injunctions, and intra-corporate disputes, resolved by the Supreme Court affirming RTC jurisdiction and granting injunctive relief.
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Case Summary (G.R. No. 184622)

Jurisdiction of the Regional Trial Court

The case revolves around the jurisdictional authority concerning intra-corporate disputes involving corporations under sequestration by the Presidential Commission on Good Government (PCGG). The Supreme Court ruled that such disputes fall under the jurisdiction of the Regional Trial Court (RTC) rather than the Sandiganbayan.

  • Intra-corporate disputes are defined as conflicts arising between stockholders, officers, or between the corporation and its members.
  • The RTC (Branch 138) was deemed appropriate to handle the case, as it did not involve sequestration-related incidents but rather an intra-corporate controversy.
  • The Sandiganbayan's jurisdiction is limited to cases involving the recovery of ill-gotten wealth and related incidents.

Consolidated Appeals Overview

The consolidated appeals include multiple petitions for review on certiorari, addressing various intra-corporate disputes among the parties involved, primarily concerning the control and management of the Philippine Overseas Telecommunications Corporation (POTC) and its subsidiaries.

  • G.R. No. 184622: Appeal from the Sandiganbayan's dismissal of an injunction complaint due to lack of jurisdiction.
  • G.R. Nos. 184712-14 and G.R. No. 186066: Appeals from the Court of Appeals regarding decisions affecting the control of POTC and its subsidiaries.
  • G.R. No. 186590: Appeal from the Ilusorio Group seeking to reverse a decision by the Court of Appeals.

Background of the Corporations Involved

POTC, PHILCOMSAT, and Philcomsat Holdings Corporation (PHC) are domestic corporations engaged in telecommunications and related services. The ownership structure indicates a complex relationship among several families and entities, with control over these corporations being a central issue in the disputes.

  • POTC is involved in constructing and operating communication satellite systems.
  • PHILCOMSAT provides telecommunications services through relay stations.
  • The ownership of these corporations is intertwined, with control over POTC affecting PHILCOMSAT and PHC.

Historical Context and Sequestration

The historical context includes the seizure of assets linked to former President Ferdinand Marcos and his associates following the EDSA People Power Revolution. The PCGG was established to recover ill-gotten wealth, leading to the sequestration of various corporations, including POTC.

  • The PCGG's actions included the surrender of properties and shares by individuals associated with Marcos.
  • The ownership structure of POTC changed significantly due to these actions, impacting the control dynamics among the families involved.

Compromise Agreement and Its Implications

A compromise agreement was reached between the government and Atty. Potenciano Ilusorio, recognizing the ownership of certain shares and altering the control dynamics within POTC. This agreement was pivotal in determining the majority control of the corporation.

  • The agreement acknowledged the Republic's ownership of 4,727 shares and Ilusorio's ownership of 673 shares.
  • The compromise agreement was approved by the Sandiganbayan, giving it the force of res judicata.

Election Controversies and Legal Proceedings

The disputes escalated into various election controversies, with competing factions claiming control over the boards of directors of POTC and PHILCOMSAT. The RTC's decisions regarding these elections were central to the appeals.

  • The RTC ruled that the elections held by the Nieto-PCGG Group were invalid due to lack of majority control.
  • The legality of proxies and the authority of directors were contested, leading to multiple legal actions.

Court of Appeals Decisions

The Court of Appeals upheld the RTC's jurisdiction and decisions, affirming that the RTC acted correctly in resolving the intra-corporate disputes without requiring a pre-trial.

  • The CA dismissed petitions questioning the RTC's authority and affirmed the validity of the RTC's decisions regarding the elections.
  • The CA's rulings emphasized the RTC's jurisdiction over intra-corporate controversies.

Supreme Court's Ruling on Jurisdiction and Appeals

The Supreme Court ultimately ruled on the jurisdictional issues, affirming the RTC's authority over the intra-corporate disputes and clarifying the proper mode of appeal for such cases.

  • The Court denied the petitions from the Nieto-PCGG Group, affirming the RTC's deci...continue reading

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