Gonzales v. GJH Land, Inc.

G.R. No. 202664

20 November 2015
SUBJECT : Remedial Law
TOPIC : Jurisdiction
FACTS :
Gonzales filed a complaint against GJH Land, Inc. (formerly known as S.J. Land,
Inc.) before the Regional Trial Court ("RTC"), Muntinlupa City seeking to enjoin
the sale of S.J. Land, Inc.’s shares. Gonzales likewise paid the assessed docket
and filing fees amounting to Php235,825.00.

In the complaint, Gonzales alleged that the subscriptions for the said shares
were already paid in full in the books of S.J. Land, Inc., yet these same shares
were again offered for sale.

The case was raffled to RTC Branch 276, which is not a Special Commercial
Court. GJH Land, Inc. filed a motion to dismiss on the ground of lack of
jurisdiction, arguing that since the case involves an intra-corporate controversy, it
should be heard by the designated Special Commercial Court of Muntinlupa City.

RTC Branch 276 granted the motion to dismiss reasoning that it had no
jurisdiction over the case since RTC Branch 256 was the branch specifically
designated by the Supreme Court as the Special Commercial Court.
ISSUE/S :
Whether or not RTC Branch 276 erred in dismissing the case for lack of
jurisdiction over the subject matter?
HELD :
Yes, the RTC Branch 276 erred in dismissing the case. The case should be
referred to the Executive Judge for re-raffling among the designated Special
Commercial Courts of the same station (i.e. RTC Branch 256 since it is the sole
designated Special Commercial Court in this case).

A court’s acquisition of jurisdiction is different from the exercise of jurisdiction.

Jurisdiction is conferred by law whereas the exercise of jurisdiction is governed
by the Rules of Court or by the orders issued of the Supreme Court.

In the instant case, from the time of filing of the intra-corporate controversy and
payment of docket and filing fees, the RTC of Muntinlupa City (station) acquired
jurisdiction over the subject matter of the case. However, RTC Branch 276, not
being a Special Commercial Court, is prohibited from exercising jurisdiction over
the intra-corporate controversy.
When a commercial case such as an intra-corporate controversy is filed in the
official RTC station but is wrongly assigned by raffle to a regular branch of that
station, the said regular branch, instead of dismissing the complaint, should first
refer the case to the Executive Judge for re-docketing as a commercial case;
thereafter, the Executive Judge should re-raffle the said case among the
designated Special Commercial Courts of that station.