Case Summary (G.R. No. 247211)
Antecedents
Pastor Y. Lim and Rufina Lim were married on September 20, 1953, and later encountered significant marital issues, leading to a series of legal actions. They initiated a Petition for the voluntary dissolution of conjugal properties in 1968, resulting in the filing for legal separation in 1971 due to Pastor's alleged infidelity. The court subsequently awarded Rufina monthly support for herself and their adopted children in a decision dated February 17, 1972.
Historical Corporate Transactions
The couple established several corporations, including Skyline International Corporation, utilizing conjugal funds. Following marital breakdowns, Rufina sought execution against assets tied to Skyline, resulting in legal disputes over the ownership and categorization of properties. On June 11, 1994, Pastor Lim died intestate, prompting Rufina to file for estate administration in 1995, which led to further disputes regarding property ownership, including the controversial Deed of Absolute Sale executed by Leslim Corporation in favor of Speed.
Legal Proceedings
The case originated from a complaint filed by Rufina against Speed Distributing Corp. and its associates in the RTC for nullifying the Deed of Absolute Sale and asserting that the properties in question were conjugal, challenging the legitimacy of the sale and the corporate resolutions that purportedly authorized it. The RTC initially dismissed the complaint, ruling that Rufina lacked standing as she was not a privy to the sale.
Court of Appeals Decision
Upon appeal, the Court of Appeals found merit in Rufina's claims, primarily focusing on the nature of the complaint which involved issues of property ownership rather than intra-corporate controversies as argued by the petitioners. The appellate court reversed the RTC decision, asserting that jurisdiction had been transferred to the RTC concerning actions originally governed by the Securities and Exchange Commission due to the enactment of Republic Act No. 8799.
Jurisdictional Analysis
The Supreme Court explored whether the RTC had jurisdiction over the complaint. The court affirmed that the nature of the dispute—focused on property rights and the status of a surviving spouse in claiming conjugal property—did not constitute an intra-corporate dispute as outlined under Presidential Decree No. 902-A. The court emphasized that jurisdiction is determined by the complaints’ allegations and not the defenses asserted by the petitioners.
Real Party in Interest
Rufina, as the surviving spouse of Pastor Lim and a compulsory heir, was qualified to file the complaint regardless of her previous exclusion from direct participation in corporate affairs. The court elucidated that inheritances are automatically conferred upon heirs at the time of a decedent’s death, allowing Rufina her r
...continue readingCase Syllabus (G.R. No. 247211)
Background of the Case
- The case involves a petition for review of a Decision by the Court of Appeals that reversed a decision made by the Regional Trial Court (RTC) of Quezon City.
- The RTC had previously dismissed a complaint filed by Rufina Lim, the private respondent, against Speed Distributing Corporation and others, concerning property ownership issues after the death of her husband, Pastor Y. Lim.
Marriage and Corporate Formation
- Pastor Y. Lim married Rufina Luy Lim on September 20, 1953, and together they formed family corporations, including Skyline International Corporation, using conjugal funds.
- The couple did not have biological children but informally adopted Leonard Lim and Lita Lim Marcelo.
- As marital issues arose, Rufina left her position at Skyline, leading to a series of legal actions, including petitions for legal separation and support.
Legal Proceedings and Corporate Issues
- A legal separation petition was filed by Rufina in 1971, resulting in a court order for monthly support.
- Following the court's decision, Rufina filed a motion for execution, leading to the sheriff levying properties of Skyline, which resulted in a dispute over the nature of those properties.
- Skyline’s claim that the properties were its own and not Pastor's led to a series of legal challenges, including a petition for certiorari that ultimately upheld the trial court's decision to disregard the corporate veil due to the intertwining of Pastor's p