View full case

MANUEL LUIS C. GONZALES v. GJH LAND

FACTS:

The petitioners filed a Complaint seeking to enjoin the sale of shares bought from S.J. Global, Inc. The case was filed with the RTC of Muntinlupa City, which was not a Special Commercial Court. Branch 276 issued a temporary restraining order and later granted a writ of preliminary injunction. Respondents filed a motion to dismiss, arguing that the case should be heard by the designated Special Commercial Court. Branch 276 granted the motion to dismiss, finding that it had no jurisdiction. Petitioners filed a motion for reconsideration, but it was denied. This led to the present petition for review on certiorari. The issue is whether or not Branch 276 erred in dismissing the case for lack of jurisdiction.

ISSUES:

  1. Whether Civil Case No. 11-077 is properly categorized as a commercial case, specifically an intra-corporate dispute.

  2. Whether the procedure to be followed when a commercial case is wrongly assigned to a regular branch of the designated Special Commercial Court.

  3. Whether the RTC of Muntinlupa City has jurisdiction over the commercial case filed by the petitioners.

  4. Whether the misroutting of the case to a regular branch of the RTC instead of the designated Special Commercial Court affects the jurisdiction of the RTC over the case.

  5. Whether the plaintiffs are entitled to injunctive relief to prevent the defendants from selling the shares of the plaintiffs.

  6. Whether the erroneous raffling of the case to a regular branch instead of a Special Commercial Court negates the jurisdiction of the RTC.

  7. Whether the RTC of Muntinlupa City can refer the case to the Executive Judge for re-docketing as a commercial case.

  8. Whether or not the RTC had acquired jurisdiction over the subject matter of the case.

  9. Whether or not the transfer of the case to the designated special court is proper.

  10. Whether the Regional Trial Court (RTC) where the case was initially filed has jurisdiction over the case.

  11. Whether the filing fee paid before misfiling is considered valid.

RULING:

  1. The Court finds that Civil Case No. 11-077 is properly categorized as a commercial case, specifically an intra-corporate dispute. The suit between the parties is rooted in the existence of an intra-corporate relationship and pertains to the enforcement of their correlative rights and obligations under the Corporation Code and the internal and intra-corporate regulatory rules of the corporation. Thus, it falls under the jurisdiction of the designated Special Commercial Court.

  2. The Court clarifies that the procedure to be followed when a commercial case, such as an intra-corporate dispute, is wrongly assigned to a regular branch of the designated Special Commercial Court is a matter of procedure and has nothing to do with the question of jurisdiction.

  3. Yes, the RTC of Muntinlupa City has jurisdiction over the commercial case filed by the petitioners. The commercial case was filed with the Office of the Clerk of Court in the RTC of Muntinlupa City, which is the official station of the designated Special Commercial Court, in accordance with A.M. No. 03-03-03-SC. Therefore, the RTC of Muntinlupa City acquired jurisdiction over the subject matter or the nature of the action from the time of such filing.

  4. The misroutting of the case to a regular branch of the RTC instead of the designated Special Commercial Court does not affect the jurisdiction of the RTC over the case. The complaint's caption, which indicated that it was a civil case for injunction, contradicts its actual allegations that clearly make out an intra-corporate dispute. The Court held that the misroutting may have been caused by a reliance on the caption, but it cannot prevail over the actual allegations of the complaint. As long as the RTC has jurisdiction over the subject matter or the nature of the action, any procedural error in the raffling or assignment of the case does not affect the jurisdiction of the court.

  5. The plaintiffs are entitled to injunctive relief to prevent the defendants from selling the shares of the plaintiffs. The court finds that the shares have been fully paid for and therefore, there is no legal or factual basis for the sale. If the plaintiffs are deprived of their shares, they would suffer irreparable damage.

  6. The erroneous raffling of the case to a regular branch instead of a Special Commercial Court does not negate the jurisdiction of the RTC. It is deemed as a procedural matter related to the exercise of jurisdiction. The proper course of action should have been for Branch 276 to refer the case to the Executive Judge for re-docketing as a commercial case and then assign it to the designated Special Commercial Court branch.

  7. The RTC of Muntinlupa City can refer the case to the Executive Judge for re-docketing as a commercial case. If the RTC has no designated Special Commercial Court branch, it should refer the case to the nearest RTC with a designated Special Commercial Court branch within the judicial region.

  8. The Court held that the RTC had acquired jurisdiction over the subject matter of the case.

  9. The Court affirmed the CA's ruling and ordered the transfer of the case to the designated special court.

  10. The misfiling of a commercial case with a court not duly designated as a Special Commercial Court is an error of jurisdiction. The RTC where the case was initially filed does not have jurisdiction over the case.

  11. The filing fee paid before misfiling is considered invalid and should be refunded or credited.

PRINCIPLES:

  • A court's acquisition of jurisdiction over a particular case's subject matter is different from incidents pertaining to the exercise of its jurisdiction. Jurisdiction over the subject matter of a case is conferred by law, while a court's exercise of jurisdiction is governed by the rules of court or orders issued by the court itself.

  • Jurisdiction over cases enumerated in Section 5 of Presidential Decree No. 902-A, including intra-corporate disputes, was transferred from the Securities and Exchange Commission (SEC) to the Regional Trial Courts (RTCs), which are courts of general jurisdiction, by virtue of the Securities Regulation Code (RA 8799).

  • Regional Trial Courts (RTCs), as courts of general jurisdiction, have exclusive original jurisdiction over all cases not within the exclusive jurisdiction of any other court, tribunal, person, or body exercising judicial or quasi-judicial functions.

  • The word "or" in Item 5.2, Section 5 of RA 8799 is used to particularize that the phrase "the Courts of general jurisdiction" is equivalent to "the appropriate Regional Trial Courts." Thus, the jurisdiction over cases previously under the SEC was transferred to the proper Regional Trial Courts.

  • The procedure to be followed when a commercial case is wrongly assigned to a regular branch of the designated Special Commercial Court is a matter of procedure and does not affect the court's jurisdiction.

  • The Supreme Court has constitutional authority to supervise the administration of all courts. (Section 6, Article VIII of the 1987 Constitution)

  • The designation of specialized courts, like Special Commercial Courts, is for the purpose of promoting expediency and efficiency in the exercise of the Regional Trial Courts' jurisdiction over specific cases. It is not related to the statutory conferment of jurisdiction on all RTCs. (Section 5 of PD 902-A)

  • The power to define, prescribe, and apportion jurisdiction among the various courts is a matter of legislative prerogative. (Section 2, Article VIII of the 1987 Constitution)

  • Injunctive relief may be granted to prevent irreparable damage when there is no legal or factual basis for a particular action.

  • The erroneous raffling of a case to a regular branch instead of a Special Commercial Court is a procedural matter related to the exercise of jurisdiction and does not negate the jurisdiction acquired by the RTC.

  • The proper course of action when a case is erroneously raffled to a regular branch is to refer the case to the Executive Judge for re-docketing as a commercial case and then assign it to the designated Special Commercial Court branch.

  • If the RTC has no designated Special Commercial Court branch, it should refer the case to the nearest RTC with a designated Special Commercial Court branch within the judicial region.

  • The designation of Special Commercial Courts is an incident related to the court's exercise of jurisdiction and does not abdicate the RTC's general jurisdiction over ordinary civil cases.

  • In cases of ordinary civil cases wrongly raffled to branches designated as Special Commercial Courts, the case should be referred to the Executive Judge for re-docketing as an ordinary civil case and then raffled off to all courts of the same RTC.

  • All transfer or raffle of cases is subject to the payment of the appropriate docket fees.

  • Misfiling a case with a court lacking jurisdiction is considered an error of jurisdiction.

  • Filing fees should be paid based on the correct court jurisdiction.

  • Filing fees that have been paid before misfiling should be refunded or credited.