Concorde Condominium v. Baculio
REITERATIONFacts
The Antecedents: Concorde Condominium, Inc. (CCI), representing unit owners, filed a Petition for Injunction with Damages against Augusto H. Baculio, New PPI Corporation, Asian Security and Investigation Agency, and various government officials. CCI sought to prevent Baculio and New PPI Corp. from claiming ownership of the condominium lots and building, to stop the security agency from deploying guards, and to restrain government officials from acting on Baculio's misrepresentations regarding building and occupancy permits and fire safety issues. CCI also prayed for damages. Procedural History: The case was raffled to the Regional Trial Court (RTC) of Makati City, Branch 149, a Special Commercial Court. During a hearing for a Temporary Restraining Order (TRO), the RTC issued an order directing the City Fire Marshal and the Building Official to conduct inspections and submit reports, and gave the unit owners an opportunity to be heard regarding the building's condemnation. Meanwhile, Baculio and New PPI Corp. filed a motion to re-raffle the case, arguing it was not an intra-corporate dispute and thus beyond the jurisdiction of a Special Commercial Court. The RTC denied this motion. Subsequently, Baculio and New PPI Corp. filed a motion to vacate the order and dismiss the case, reiterating the lack of jurisdiction. On June 28, 2012, the RTC dismissed the case for lack of jurisdiction, finding no intra-corporate relations and deeming it an ordinary civil action. The RTC denied CCI's motion for reconsideration. The Petition: CCI filed a Petition for Review on Certiorari with the Supreme Court, assailing the RTC's dismissal for lack of jurisdiction.
Issue(s)
Whether the Regional Trial Court (RTC), Branch 149, a designated Special Commercial Court, erred in dismissing the petition for injunction with damages for lack of jurisdiction over the subject matter. Whether the petition for injunction with damages is an ordinary civil case or an intra-corporate controversy.
Ruling
The Supreme Court granted the petition, reversed and set aside the orders of the RTC dismissing the case, reinstated Civil Case No. 12-309, and ordered the RTC, Branch 149, to resolve the case with reasonable dispatch.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the RTC, Branch 149, erred in dismissing the petition for lack of jurisdiction. The Court reiterated the principle that jurisdiction over the subject matter is conferred by law and is determined by the allegations in the complaint. Actions for injunction and damages generally fall within the jurisdiction of the RTC, as provided by Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980), particularly Section 19 concerning civil actions where the subject matter is incapable of pecuniary estimation. The Court emphasized that the designation of certain RTC branches as Special Commercial Courts does not divest them of their general jurisdiction; these branches remain courts of general jurisdiction with the power to hear and decide cases of all natures, whether civil, criminal, or special proceedings. The transfer of jurisdiction over cases enumerated under Section 5 of Presidential Decree No. 902-A from the Securities and Exchange Commission (SEC) to the RTCs by virtue of Republic Act No. 8799 meant that RTCs, as courts of general jurisdiction, acquired this power, and the Supreme Court's designation of specific branches as Special Commercial Courts was merely for streamlining and expediting the resolution of commercial cases, not to limit their inherent jurisdiction. Therefore, Branch 149, as a court of general jurisdiction, retained the authority to hear the ordinary civil action for injunction filed by CCI. On whether the case is an intra-corporate controversy: Applying the relationship test and the nature of the controversy test, the Court agreed with the RTC's finding that the case is an ordinary civil action and not an intra-corporate controversy. The allegations in the petition did not establish any intra-corporate relations between the parties, specifically between CCI (the condominium corporation and its unit owners) and respondent New PPI Corporation (claiming ownership of the lots and building). The dispute primarily concerned conflicting claims of ownership over the lots and the building, and alleged violations of the National Building Code, which are matters falling under the general jurisdiction of the RTC, not exclusive SEC jurisdiction prior to R.A. 8799. The Court noted that the previous ruling by the Housing and Land Use Regulatory Board (HLURB) in favor of CCI regarding vested rights over the subject lots further supported the nature of the dispute as a civil matter concerning property rights and claims, rather than an internal corporate dispute. The presence of government officials as respondents, acting on alleged misrepresentations and violations of building codes, also pointed towards an ordinary civil action involving property rights and administrative compliance, not an internal corporate matter.
Main Doctrine
A Regional Trial Court (RTC) branch designated as a Special Commercial Court retains its general jurisdiction and can hear ordinary civil cases, including actions for injunction, as its designation does not divest it of its inherent power as a court of general jurisdiction.