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MANUEL LUIS GONZALES, et al. vs. GJH LAND, INC. et al.

jurisdiction, unless provided by the law itself, is governed by the Rules of


J. Perlas-Bernabe | November 20, 2015 Court or by the orders issued from time to time by the Court. In Lozada v.
Bracewell, it was recently held that the matter of whether the RTC resolves
On Aug. 4, 2011, Gonzales et al filed a complaint for “Injunction with prayer an issue in the exercise of its general jurisdiction or of its limited jurisdiction
for Issuance of Status Quo Order, 3 and 20 day TROs, and WPI with as a special court is only a matter of procedure and has nothing to do with
Damages” against GJH Land et al before RTC Muntinlupa seeking to enjoin the question of jurisdiction.
the sale of SJ Land’s share which they purportedly bought from SJ Global on
Feb. 1, 2010. Essentially, Gonzales et al alleged that the subscriptions for Pertinent to this case is RA 8799 which took effect on August 8, 2000. By
the said shares were already paid by them in the books of SJ Land but were virtue of said law, jurisdiction over cases enumerated in Section 5 of
nonetheless offered for sale on July 29, 2011 to the corporation’s Presidential Decree No. 902-A was transferred from the Securities and
stockholders, hence, their plea for injunction. Exchange Commission (SEC) to the RTCs, being courts of general
jurisdiction.
The case was raffled to Branch 276 which is not a Special Commercial
Court. On Aug. 9, 2011, Branch 276 issued a TRO and later an Order dated The legal attribution of Regional Trial Courts as courts of general jurisdiction
Aug. 24, granting the application for a WPI. stems from Section 19 (6), Chapter II of Batas Pambansa Bilang (BP) 129,
known as "The Judiciary Reorganization Act of 1980."
After filing their answers, GJH Land et al filed a motion to dismiss on the
ground of lack of jurisdiction over the subject matter, pointing out that the As enunciated in Durisol Philippines, Inc. v. CA: The regional trial court,
case involves an intra-corporate dispute and should, thus, be heard by the formerly the court of first instance, is a court of general jurisdiction. All cases,
designated Special Commercial Court of Muntinlupa. the jurisdiction over which is not specifically provided for by law to be within
the jurisdiction of any other court, fall under the jurisdiction of the regional
Branch 276 granted the motion to dismiss on the ground that the case trial court.
involves an intra-corporate dispute that is within the original and exclusive
jurisdiction of Special Commercial Courts which is Branch 256.

ISSUE / RATIO

WON Branch 276 of RTC Muntinlupa erred in dismissing the case for
lack of jurisdiction over the subject matter – YES

At the outset, the Court finds Branch 276 to have correctly categorized Civil
Case No. 11-077 as a commercial case, more particularly, an intra-corporate
dispute, considering that it relates to petitioners' averred rights over the
shares of stock offered for sale to other stockholders, having paid the same
in full.

The present controversy lies, however, in the procedure to be followed when


a commercial case - such as the instant intra-corporate dispute -has been
properly filed in the official station of the designated Special Commercial
Court but is, however, later wrongly assigned by raffle to a regular branch of
that station.

As a basic premise, let it be emphasized that 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, whereas a court's exercise of

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