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Jurisdiction in Gonzales v. GJH Land

Gonzales filed a complaint against GJH Land, Inc. in the Regional Trial Court (RTC) of Muntinlupa City regarding the sale of the company's shares. The case was assigned to RTC Branch 276, which is not a designated Special Commercial Court. GJH Land filed a motion to dismiss for lack of jurisdiction, which was granted. The Supreme Court held that while RTC Branch 276 did not have authority to hear the intra-corporate case, the RTC station had proper jurisdiction once fees were paid. The case should have been referred to the Executive Judge for reassignment to the designated Special Commercial Court, RTC Branch 256, rather than dismissed.

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1K views2 pages

Jurisdiction in Gonzales v. GJH Land

Gonzales filed a complaint against GJH Land, Inc. in the Regional Trial Court (RTC) of Muntinlupa City regarding the sale of the company's shares. The case was assigned to RTC Branch 276, which is not a designated Special Commercial Court. GJH Land filed a motion to dismiss for lack of jurisdiction, which was granted. The Supreme Court held that while RTC Branch 276 did not have authority to hear the intra-corporate case, the RTC station had proper jurisdiction once fees were paid. The case should have been referred to the Executive Judge for reassignment to the designated Special Commercial Court, RTC Branch 256, rather than dismissed.

Uploaded by

Dee Comon
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd

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.

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