CONCORDE CONDOMINIUM v. AUGUSTO H.

BACULIO
G.R. No. 203678, February 17, 2016

DOCTRINE

The matter of whether the RTC resolves an issue in the exercise of its general jurisdiction or of its
limited jurisdiction as a special court is only a matter of procedure and has nothing to do with the
question of jurisdiction.

FACTS

Petitioner Concorde Condominium, Inc., filed with the Regional Trial Court of Makati City a
Petition for Injunction against respondents New PPI Corporation and its President Augusto H.
Baculio. The case was raffled to the Makati RTC, Branch 149, which was designated as a Special
Commercial Court.

Petitioner seeks to enjoin respondents from misrepresenting to the public, that they are the owners
of the disputed lots and Concorde Condominium Building, and from pushing for the demolition of
the building which they do not even own, and also for damages.

The respondents claimed that that there is no showing that the case involves a matter embraced in
Section 5 of Presidential Decree (P.D.) No. 902-A, over which the RTC sitting as special
commercial court which has jurisdiction, but the regular courts.

The RTC sitting as special commercial court dismissed the case for lack of jurisdiction, ruling that
the case does not involve an intra-corporate controversy cognizable by it. It is the regular courts
which has jurisdiction.

ISSUE

WON RTC committed a manifest error of law in dismissing the petition on the ground of lack of
jurisdiction.

RULING

Yes. The jurisdiction of the SEC over intra-corporate cases was transferred to Courts of general
jurisdiction or the appropriate Regional Trial Court when R.A. No. 8799 took effect on August 8,
2000.

A careful review of the allegations in the petition for injunction with damages, indicates no intra-
corporate relations exists between the opposing parties. Therefore, the matter of the petition is in
the nature of an ordinary civil action. However, the designation of Special Commercial Courts was
merely intended as a procedural tool to expedite the resolution of commercial cases in line with
the court's exercise of jurisdiction. As a court of general jurisdiction, it still has jurisdiction over
the subject matter thereof.