G.R. No. 125221 – 274 SCRA 452 – Mercantile Law – Corporation Law – Jurisdiction of the SEC
Reynaldo Lozano was the president of KAMAJDA (Kapatirang Mabalacat-Angeles Jeepney Drivers’ Association, Inc.). Antonio Anda was the president of SAMAJODA (Samahang Angeles-Mabalacat Jeepney Operators’ and Drivers’ Association, Inc.). In 1995, the two agreed to consolidate the two corporations, thus, UMAJODA (Unified Mabalacat-Angeles Jeepney Operators’ and Drivers Association, Inc.). In the same year, elections for the officers of UMAJODA were held. Lozano and Anda both ran for president. Lozano won but Anda alleged election fraud and thereafter he refused to participate with UMAJODA. Anda continued to collect fees from members of SAMAJODA and refused to recognize Lozano as president of UMAJODA. Lozano then filed a complaint for damages against Anda with the MCTC of Mabalacat (and Magalang), Pampanga. Anda moved for the dismissal of the case for lack of jurisdiction. The MCTC judge denied Anda’s motion. On certiorari, Judge Eliezer De Los Santos of RTC Angeles City reversed and ordered the dismissal of the case on the ground that what is involved is an intra-corporate dispute which should be under the jurisdiction of the Securities and Exchange Commission (SEC).
ISSUE: Whether or not the RTC Judge is correct.
HELD: No. The regular courts have jurisdiction over the case. The case between Lozano and Anda is not an intra-corporate dispute. UMAJODA is not yet incorporated. It is yet to submit its articles of incorporation to the SEC. It is not even a dispute between KAMAJDA or SAMAJODA. The controversy between Lozano and Anda does not arise from intra-corporate relations but rather from a mere conflict from their plan to merge the two associations.
NOTE: Regular courts can now hear intra-corporate disputes (expanded jurisdiction).
