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CONCORDE CONDOMINIUM v. AUGUSTO H. BACULIO

FACTS:

Petitioner Concorde Condominium, Inc. filed a Petition for Injunction with Damages against several respondents, seeking to enjoin them from misrepresenting ownership of a building and pushing for its demolition. They also sought to prevent the deployment of security guards by a certain agency within the perimeter of the said building. The case was raffled to the Regional Trial Court (RTC) of Makati City, Branch 149, a Special Commercial Court. During a hearing, the RTC ordered the Fire Marshal and the Building Official of Makati City to conduct investigations on the building and submit reports to the court. The President of the condominium corporation was given four months to remedy the building's problems and deficiencies. Meanwhile, respondents filed a motion seeking to re-raffle the case to a regular court, claiming lack of jurisdiction. The RTC denied the motion, leading respondents to file a motion to dismiss, asserting that the case is beyond the jurisdiction of a Special Commercial Court.

The case involves a petition for injunction with damages filed by Concorde Condominium Corporation against Baculio, New PPI Corporation, and other respondents. The case was filed with the Regional Trial Court (RTC), but the RTC dismissed the case for lack of jurisdiction. The RTC held that the case does not involve an intra-corporate controversy and therefore is not within its jurisdiction as a Special Commercial Court. The RTC also noted that the respondents are not owners of the subject lots and building. The petitioner filed a motion for reconsideration, which the RTC denied. Hence, the petitioner filed a petition for review on certiorari. The petitioner argues that the case is an ordinary civil case correctly filed with the RTC and that the designation of the RTC branch as a Special Commercial Court did not divest it of its power as a court of general jurisdiction. The respondents, on the other hand, argue that the case should be dismissed for lack of proper verification, lack of cause of action, and failure to exhaust administrative remedies.

The petitioner filed a petition for injunction with damages before Branch 149 of the Makati RTC against the respondent Office of the Building Official of Makati City. The petitioner alleged that the respondent failed to correct several violations of the National Building Code in its building despite several demands and extensions made by the Building Official. The respondent filed a Comment/Opposition, arguing that the petition should be dismissed for failure to exhaust administrative remedies, that Branch 149 has jurisdiction over the case as a Special Commercial Court, and that the violations in the petitioner's building were not corrected. In resolving the issue of jurisdiction, the Court cited Section 19 of Batas Pambansa Blg. 129, which grants the RTC jurisdiction over civil actions incapable of pecuniary estimation or those not within the exclusive jurisdiction of any other court. It also mentioned P.D. No. 902-A, which originally granted the SEC jurisdiction over intra-corporate cases but was later transferred to courts of general jurisdiction. The Court further clarified that Special Commercial Courts are still considered as courts of general jurisdiction and have the power to hear cases of all nature.

In this case, the Supreme Court addressed the issue of whether an RTC exercising jurisdiction over an intra-corporate dispute can also hear and decide cases under Sections 56 and 57 of the Comprehensive Agrarian Reform Law (CARL). It was argued that the designation of Special Commercial Courts (SCCs) to hear and decide intra-corporate disputes under the Interim Rules of Procedure on Corporate Rehabilitation and Financial Rehabilitation Cases should be limited to such cases. However, the Court clarified that the designation of SCCs did not restrict their jurisdiction to hear and decide cases of all nature, including civil, criminal, or special proceedings.

ISSUES:

  1. Whether Special Commercial Courts (SCCs) have limited jurisdiction or can hear and decide cases of all nature.

  2. Whether the transfer of jurisdiction over cases enumerated in Section 5 of P.D. 902-A was made to the RTCs in general or only in favor of particular RTC branches.

  3. Whether Branch 149 of the Makati RTC has jurisdiction over the subject matter of the case.

  4. Whether the transfer of jurisdiction was made only in favor of particular RTC branches, and not the RTCs in general.

  5. Whether respondents Baculio and New PPI Corp. should be restrained from misrepresenting ownership of the Concorde Condominium Building and pushing for its demolition.

  6. Whether respondent Asian Security and Investigation Agency should be ordered to leave the premises.

  7. Whether respondent Engr. Nelson Morales should be enjoined from entertaining and acting upon Baculio's letters, as well as from implementing the revocation of petitioner's building and occupancy permit.

  8. Whether respondents Supt. Ricardo C. Perdigon and F/C Supt. Santiago E. Laguna should be directed to issue the necessary permits for the installation of a fire sprinkler system and to correct other fire safety deficiencies.

  9. Whether Civil Case No. 12-309 for injunction with damages is an intra-corporate controversy.

  10. Whether the designation of a branch as a Special Commercial Court diminishes its power as a court of general jurisdiction to hear and decide cases of all nature.

  11. Whether or not the CA erred in reversing and setting aside the decision of the RTC.

  12. Whether or not the CA erred in ordering the reinstatement of Civil Case No. 12-309 in the docket of the same branch of the RTC.

RULING:

  1. SCCs are considered courts of general jurisdiction and have the power to hear and decide cases of all nature, whether civil, criminal, or special proceedings.

  2. The transfer of jurisdiction over cases enumerated in Section 5 of P.D. 902-A was made to the RTCs in general, and not only in favor of particular RTC branches (SCCs).

  3. Yes, Branch 149 of the Makati RTC has jurisdiction over the subject matter of the case. Both the designated Special Commercial Courts and the regular RTCs are conferred by law the power to hear and decide civil cases in which the subject of the litigation is incapable of pecuniary estimation, such as an action for injunction.

  4. No, the transfer of jurisdiction was not made only in favor of particular RTC branches. The designated Special Commercial Courts and the regular RTCs, as courts of general jurisdiction, are both authorized to hear and decide civil cases in which the subject of the litigation is incapable of pecuniary estimation.

  5. Respondents Baculio and New PPI Corp. should be permanently enjoined from misrepresenting ownership of the Concorde Condominium Building and pushing for its demolition.

  6. Respondent Asian Security and Investigation Agency should be ordered to leave the premises.

  7. Respondent Engr. Nelson Morales should be restrained from entertaining and acting upon Baculio's letters and from implementing the revocation of petitioner's building and occupancy permit.

  8. Respondents Supt. Ricardo C. Perdigon and F/C Supt. Santiago E. Laguna should be directed to issue the necessary permits for the installation of a fire sprinkler system and to correct other fire safety deficiencies.

  9. Civil Case No. 12-309 for injunction with damages is not an intra-corporate controversy. The suit does not arise from an intra-corporate relationship nor does it pertain to the enforcement of correlative rights and obligations under the Corporation Code or internal and intra-corporate regulatory rules of the corporation.

  10. The designation of a branch as a Special Commercial Court does not diminish its power as a court of general jurisdiction to hear and decide cases of all nature. The Makati RTC, Branch 149, has jurisdiction over the subject matter of the petition for injunction with damages, which is an ordinary civil case.

  11. The Supreme Court held that the CA erred in reversing and setting aside the decision of the RTC. It ruled that the CA did not have the power to reverse the factual findings of the RTC absent palpable error or grave abuse of discretion. The Supreme Court found that the RTC's factual findings were supported by the evidence on record and should be accorded respect and finality.

  12. The Supreme Court also held that the CA erred in ordering the reinstatement of Civil Case No. 12-309 in the docket of the same branch of the RTC. It ruled that this order was unnecessary as the RTC had already rendered a decision in the case. The Supreme Court ordered the CA decision to be reversed and set aside, and Civil Case No. 12-309 to be reinstated in the docket of the same branch of the RTC.

PRINCIPLES:

  • The designation of certain RTC branches to handle specific cases is not new and does not limit their jurisdiction to hear and decide cases of all nature.

  • A court's acquisition of jurisdiction over a particular case's subject matter is different from incidents pertaining to the exercise of its jurisdiction. The matter of whether the RTC resolves an issue in the exercise of its general jurisdiction or limited jurisdiction as a special court is only a matter of procedure and does not affect jurisdiction.

  • Jurisdiction over cases enumerated in Section 5 of P.D. 902-A was transferred from the Securities and Exchange Commission (SEC) to the RTCs, being courts of general jurisdiction.

  • The word "or" in Item 5.2, Section 5 of R.A. No. 8799 was intentionally used to indicate that the phrase "the Courts of general jurisdiction" is equivalent to the phrase "the appropriate Regional Trial Court." Therefore, the jurisdiction of the SEC over cases enumerated in Section 5 of P.D. 902-A was transferred to the proper Regional Trial Courts.

  • The Securities and Exchange Commission (SEC) has been authorized to reorganize itself and retain only certain quasi-judicial functions.

  • The designated Special Commercial Courts and the regular RTCs have the power to hear and decide civil cases in which the subject of the litigation is incapable of pecuniary estimation.

  • The transfer of jurisdiction was not limited to particular RTC branches, but applies to all RTCs as courts of general jurisdiction.

  • An action for injunction aims to enjoin the defendant from the commission or continuance of a specific act, or to compel the defendant to continue performance of a particular act. It has an independent existence from the ancillary remedy of preliminary injunction. The auxiliary remedy of preliminary injunction may only exist as part of an independent action or proceeding.

  • A false representation of ownership and pushing for the demolition of a building that one does not own violates the rights of the true owner to undisturbed ownership, possession, and peaceful enjoyment of their property.

  • Security guards stationed within the premises of a building without authority poses a threat and causes fear and anxiety to the unit owners, warranting their removal.

  • Government officials should not entertain and act upon letters and requests from individuals who have no legal personality or authority with regard to the matters concerned.

  • Government agencies responsible for fire safety and regulations should issue necessary permits for the installation of fire safety systems and the correction of deficiencies to ensure compliance and safety.

  • In determining whether a dispute constitutes an intra-corporate controversy, the relationship test and the nature of the controversy test should be applied.

  • The designation of Special Commercial Courts is a procedural tool to expedite the resolution of commercial cases but does not abdicate the RTC's general jurisdiction over ordinary civil cases.

  • The designation of Special Commercial Courts is made by an internal Supreme Court rule and does not go beyond the statutory law.

  • The CA does not have the power to reverse the factual findings of the RTC absent palpable error or grave abuse of discretion.

  • Factual findings of the RTC, supported by evidence on record, should be accorded respect and finality.