Mercantile Law

GONZALES v. GJH LAND, INC. G.R. No. 202664, November 20, 2015 Inta-corporate Dispute, Jurisdiction


Petitioners filed a Complaint for Injunction with prayer for Issuance of Status Quo Order, Temporary Restraining Orders, and Writ of Preliminary Injunction with Damages against respondents before the RTC of Muntinlupa City seeking to enjoin the sale of their shares of stock which they purportedly bought and already paid by them in full, but were nonetheless offered for sale on to the corporation’s stockholders.

The case was raffled to Branch 276, which is not a Special Commercial Court. Said branch issued a temporary restraining order, and later, an Order granting the application for a writ of preliminary injunction.

Respondents filed a motion to dismiss on the ground of lack of jurisdiction over the subject matter, pointing out that the case involves an intra-corporate dispute and should, thus, be heard by the designated Special Commercial Court of Muntinlupa City.

The RTC granted the motion to dismiss.

Petitioners’ motion for reconsideration was denied. Hence, the present petition.


Whether or not Branch 276 of the RTC of Muntinlupa City erred in dismissing the case for lack of jurisdiction over the subject matter.


The petition is meritorious.

Applying the relationship test and the nature of the controversy test, the suit between the parties is clearly rooted in the existence of an intra-corporate relationship and pertains to the enforcement of their correlative rights and obligations under the Corporation Code and the internal and intra-corporate regulatory rules of the corporation, hence, intra-corporate, which should be heard by the designated Special Commercial Court as provided under A.M. No. 03-03-03-SC in relation to Item 5.2, Section 5 of RA 8799.

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.

The instant petition is granted. The Orders of the RTC of Muntinlupa City, Branch 276 are reversed and set aside. The Executive Judge shall assign said case to Branch 256, the sole designated Special Commercial Court in the RTC of Muntinlupa City.

Leave a Reply

Your email address will not be published. Required fields are marked *