The jurisdiction over commercial cases, including intra-corporate disputes, is conferred by Republic Act No. 8799 upon Regional Trial Courts as courts of general jurisdiction, and the Supreme Court's designation of certain RTC branches as Special Commercial Courts is an administrative and procedural measure to promote expediency and efficiency in the exercise of that jurisdiction, not a conferment of jurisdiction itself; therefore, a commercial case erroneously raffled to a regular RTC branch within a station that has a designated Special Commercial Court should be transferred to the latter, not dismissed for lack of jurisdiction.

The case arose from a dispute over shares in S.J. Land, Inc. (later GJH Land, Inc.). Petitioners claimed they had fully paid for their subscribed shares, but these shares were subsequently offered for sale to other stockholders by the corporation, prompting petitioners to seek an injunction. This underlying dispute was recognized as an intra-corporate controversy.

• On August 4, 2011, petitioners Manuel Luis C. Gonzales and Francis Martin D. Gonzales filed a complaint for "Injunction with prayer for Issuance of Status Quo Order, Three (3) and Twenty (20)-Day Temporary Restraining Orders, and Writ of Preliminary Injunction with Damages" before the RTC of Muntinlupa City.
• The complaint sought to enjoin respondents GJH Land, Inc. (formerly S.J. Land, Inc.), Chang Hwan Jang, Sang Rak Kim, Mariechu N. Yap, and Atty. Roberto P. Mallari II from selling shares of S.J. Land, Inc. that petitioners claimed they had purchased from S.J. Global, Inc. on February 1, 2010, and had fully paid for in the books of S.J. Land, Inc.
• Despite petitioners' alleged full payment, these shares were offered for sale to the corporation's stockholders on July 29, 2011, with the offer opening on August 10, 2011.
• The complaint was docketed as Civil Case No. 11-077 and raffled to Branch 276 of the RTC Muntinlupa City, which is not a designated Special Commercial Court. Branch 256 was the designated Special Commercial Court for Muntinlupa City.
• Branch 276 initially issued a temporary restraining order and subsequently granted a writ of preliminary injunction.
• The allegations in the complaint, specifically paragraphs 16 to 21, detailed demands for payment of alleged unpaid subscriptions by GJH Land, Inc., the subsequent offer for sale of petitioners' shares, and petitioners' assertion that their shares were fully paid, indicating an intra-corporate dispute regarding share ownership and rights.

• The raffle of the case to Branch 276 (a regular court) instead of Branch 256 (the Special Commercial Court) was beyond their control, and they should not suffer from this erroneous assignment, especially after paying substantial filing fees.
• The RTC, in general, has jurisdiction over intra-corporate disputes under Republic Act No. 8799 (Securities Regulation Code).
• Since the Supreme Court merely selected specific branches (Special Commercial Courts) to hear such suits for expediency, the case should, at most, be transferred or re-raffled to the proper Special Commercial Court, not dismissed.
• The RTC Branch 276's reliance on Calleja v. Panday was improper due to factual differences, as Calleja involved filing in an RTC that had no designated Special Commercial Court branch at all, unlike the present case where both the regular branch and the Special Commercial Court are within the same RTC of Muntinlupa City.

• The RTC Branch 276 lacked jurisdiction over the subject matter of the complaint.
• The case involves an intra-corporate dispute, which falls under the original and exclusive jurisdiction of RTCs designated as Special Commercial Courts.
• Since Branch 276 was not a designated Special Commercial Court, it could not lawfully exercise jurisdiction, and the case should be dismissed. (This was raised in their motion to dismiss before the RTC).

• Whether or not RTC Branch 276 of Muntinlupa City erred in dismissing Civil Case No. 11-077 for lack of jurisdiction over the subject matter on the ground that it is a regular branch and not the designated Special Commercial Court.
• What is the proper procedure when a commercial case is filed in the official station of the designated Special Commercial Court but is wrongly raffled to a regular branch of that station?

• The Supreme Court granted the petition, reversing and setting aside the RTC Branch 276's orders of dismissal.
• The Court held that RTC Branch 276 correctly categorized the case as an intra-corporate dispute, which is a commercial case.
• Jurisdiction over the subject matter is conferred by law (RA 8799 for commercial cases, transferring SEC's former jurisdiction to RTCs). The RTC of Muntinlupa City, as a whole, acquired jurisdiction over the subject matter from the time the complaint was filed with its Office of the Clerk of Court, which is the official station of the designated Special Commercial Court (Branch 256).
• The designation of specific RTC branches as Special Commercial Courts by the Supreme Court (under A.M. No. 03-03-03-SC) is a matter of procedure relating to the exercise of jurisdiction, aimed at promoting expediency and efficiency, and does not diminish or confer statutory jurisdiction.
• The erroneous raffling of the commercial case to Branch 276 (a regular branch) instead of its assignment to Branch 256 (the sole Special Commercial Court in Muntinlupa RTC) was a procedural error that should not negate the jurisdiction already acquired by the RTC of Muntinlupa City.
• The proper course of action was not dismissal, but for Branch 276 to refer the case to the Executive Judge for re-docketing as a commercial case, and for the Executive Judge to then assign it to Branch 256.
• The Court distinguished Calleja v. Panday, stating it was improperly relied upon by the RTC as it involved filing in an RTC (San Jose, Camarines Sur) that had no internal branch designated as a Special Commercial Court, unlike the instant case. Tan v. Bausch & Lomb, Inc. was cited as a more appropriate precedent supporting transfer.
• The Court set aside the dismissal and ordered Civil Case No. 11-077 to be referred to the Executive Judge of RTC Muntinlupa City for re-docketing as a commercial case and assignment to Branch 256 for resolution.
• The Court also laid down new procedural guidelines for: (1) commercial cases wrongly raffled to regular RTC branches, (2) ordinary civil cases wrongly raffled to Special Commercial Courts, (3) handling of docket fees in such transfers/raffles, and (4) requiring initiatory pleadings to state the action's nature in both caption and body.

• Jurisdiction over Subject Matter vs. Exercise of Jurisdiction — Jurisdiction over the subject matter is the power to hear and determine cases of the general class to which the proceedings in question belong and is conferred by law. Exercise of jurisdiction is governed by the Rules of Court or by Supreme Court orders and pertains to procedural incidents. This was applied to distinguish between the RTC's statutory jurisdiction over commercial cases (conferred by RA 8799) and the SC's designation of Special Commercial Courts (an exercise of jurisdiction for efficiency).
• Nature of Action Determined by Allegations — The nature of an action is determined by the allegations in the complaint and the character of the relief sought, not by its caption. This was applied to confirm that the case was an intra-corporate dispute despite its caption as a "Civil Case for Injunction," based on the factual averments within the complaint.
• Statutory Conferment of Jurisdiction — The power to define, prescribe, and apportion jurisdiction of various courts belongs to Congress. The Supreme Court cannot enlarge, diminish, or dictate when jurisdiction shall be removed. This was invoked to clarify that the SC's designation of Special Commercial Courts does not alter the statutory grant of jurisdiction to RTCs over commercial cases under RA 8799.
• Administrative Supervision of Courts by the Supreme Court — The Supreme Court has administrative supervision over all courts and their personnel (Constitution, Art. VIII, Sec. 6). This power, along with its rule-making power, is the basis for designating Special Commercial Courts to promote expediency and efficiency.
• Statutory Construction (Legislative Intent for "or") — The word "or" in Item 5.2, Section 5 of RA 8799 ("Courts of general jurisdiction or the appropriate Regional Trial Court") was interpreted as equivalent to "that is to say," meaning jurisdiction was transferred to RTCs, which are courts of general jurisdiction. This interpretation was supported by congressional deliberations.

• "Jurisdiction over the subject matter of a case is conferred by law, whereas a court's exercise of jurisdiction, unless provided by the law itself, is governed by the Rules of Court or by the orders issued from time to time by the Court."
• "[T]he matter of whether the RTC resolves an issue in the exercise of its general jurisdiction or of its limited jurisdiction as a special court is only a matter of procedure and has nothing to do with the question of jurisdiction."
• "[I]t is not the caption but the allegations in the complaint or other initiatory pleading which give meaning to the pleading and on the basis of which such pleading may be legally characterized."
• "The objective behind the designation of such specialized courts is to promote expediency and efficiency in the exercise of the RTCs' jurisdiction over the cases enumerated under Section 5 of PD 902-A. Such designation has nothing to do with the statutory conferment of jurisdiction to all RTCs under RA 8799..."

• Lozada v. Bracewell — Cited to support the distinction that whether an RTC resolves an issue under its general or special (e.g., as a commercial court) jurisdiction is a matter of procedure, not of jurisdiction itself.
• Durisol Philippines, Inc. v. CA — Cited to affirm that Regional Trial Courts are courts of general jurisdiction.
• San Miguel Corp. v. Municipal Council — Cited for the statutory construction principle that "or" can mean "that is to say," supporting the interpretation that RA 8799 transferred jurisdiction to RTCs as courts of general jurisdiction.
• Calleja v. Panday — Distinguished. The RTC mistakenly relied on this case. Calleja involved a commercial case filed in an RTC (San Jose, Camarines Sur) which had no designated Special Commercial Court branch, with the proper SCC being in a different RTC (Naga City), leading to dismissal. The instant case involves a single RTC (Muntinlupa) with both a regular branch and a designated SCC. The SC also noted that Calleja blurred the line between subject matter jurisdiction and exercise of jurisdiction.
• Tan v. Bausch & Lomb, Inc. — Cited as the appropriate jurisprudential reference. In Tan, an intellectual property case was wrongly raffled to a regular branch of the RTC of Cebu City instead of its designated Special Commercial Court. The Supreme Court affirmed the CA's order to transfer the case to the SCC of the same RTC, supporting transfer over dismissal in the present case.
• Republic of the Phils. v. Nolasco — Cited for the principle that the allegations in the complaint, not its caption, determine the nature of the action.

• Republic Act No. 8799 (The Securities Regulation Code), Item 5.2, Section 5 — This provision transferred the SEC's jurisdiction over cases enumerated in PD 902-A, Section 5 to the "Courts of general jurisdiction or the appropriate Regional Trial Court," and authorized the Supreme Court to designate RTC branches to exercise jurisdiction over these cases. It is the statutory basis for RTCs having jurisdiction over commercial cases.
• Presidential Decree No. 902-A, Section 5 — Enumerates the types of cases (including intra-corporate disputes) formerly under the SEC's jurisdiction, which were transferred to the RTCs by RA 8799.
• Batas Pambansa Bilang 129 (The Judiciary Reorganization Act of 1980), Section 19(6) — Establishes RTCs as courts of general jurisdiction, supporting the view that jurisdiction over commercial cases was transferred to RTCs in general.
• A.M. No. 03-03-03-SC ("Consolidation of Intellectual Property Courts with Commercial Courts") — This SC issuance designated Special Commercial Courts and mandated that commercial cases be filed in the Office of the Clerk of Court in the official station of the designated SCC. The Court clarified this is a procedural rule for efficiency.
• 1987 Constitution, Article VIII, Section 6 — Grants the Supreme Court administrative supervision over all courts. This is the constitutional basis for the SC's designation of Special Commercial Courts for expediency.
• 1987 Constitution, Article VIII, Section 2 — Vests in Congress the power to define, prescribe, and apportion the jurisdiction of various courts. This was cited to emphasize that the SC's designation of SCCs does not alter statutory jurisdiction.
• SC Administrative Circular No. 08-2001 — Directed the transfer of SEC cases already distributed to regular RTC branches to the newly designated commercial SEC courts. Part of the historical development of SCCs.

• Justice Teresita J. Leonardo-De Castro — Concurred in the result. She subscribed to the ruling in Calleja that misfiling of a commercial case with a court not duly designated as a Special Commercial Court is an error of jurisdiction. However, she agreed that the Supreme Court has the constitutional and legal basis (RA 8799) to promulgate the guidelines set forth in the ponencia for future cases.
• Justice Marvic M.V.F. Leonen — Concurred fully with the ponencia. He emphasized that jurisdiction over SEC cases was vested by RA 8799 in Regional Trial Courts generally, not limited to designated Special Commercial Courts. The legislature alone has the power to define jurisdiction. The SC's designation of SCCs is an exercise of its administrative supervision and rule-making power for operational efficiency and does not confer jurisdiction. He distinguished this from Family Courts, which were created by a specific statute (RA 8369) that defined their exclusive original jurisdiction.

• Justice Jose Portugal Perez — Dissented, arguing that Section 5.2 of RA 8799, when read as a whole with its proviso, means that jurisdiction over SEC cases was transferred not to all RTCs generally, but only to those specific RTC branches designated by the Supreme Court. He contended that the SC's designation defines the conferred jurisdiction, not merely its exercise. Thus, a regular RTC branch (like Branch 276) has no jurisdiction over an intra-corporate dispute, and the case should be dismissed, not transferred. He also faulted petitioners for incorrectly labeling their complaint, which contributed to the erroneous raffling.