Gonzales, et al. vs. GJH Land, Inc., et al.

Jurisdiction over intra-corporate disputes is vested by RA 8799 in the Regional Trial Courts as courts of general jurisdiction; the SC's designation of specific branches as Special Commercial Courts is merely a procedural incident related to the exercise of jurisdiction, not a conferment of subject matter jurisdiction. Erroneous raffling to a regular branch requires transfer to the designated branch, not dismissal.

With the enactment of RA 8799 (Securities Regulation Code), jurisdiction over intra-corporate disputes was transferred from the Securities and Exchange Commission (SEC) to the RTCs. To implement this, the SC designated specific RTC branches as Special Commercial Courts to promote expediency and efficiency. A procedural question arose when cases properly filed in the official station of an RTC were wrongly raffled to regular branches instead of the designated special branches.

• Original Filing: RTC of Muntinlupa City, Civil Case No. 11-077
• Lower Court Decision: April 17, 2012 — Branch 276 granted the motion to dismiss for lack of jurisdiction.
• Motion for Reconsideration: July 9, 2012 — Branch 276 denied the motion, citing Calleja v. Panday.
• SC Action: Direct recourse via Petition for Review on Certiorari challenging the RTC dismissal orders.

• The Dispute: Petitioners Manuel Luis C. Gonzales and Francis Martin D. Gonzales subscribed to shares in S.J. Land, Inc. (later GJH Land, Inc.), claiming they paid in full. Respondents (corporate officers) claimed the subscriptions were unpaid and offered these shares for sale to other stockholders.
• The Filing: On August 4, 2011, petitioners filed a Complaint for Injunction with TRO and damages to stop the sale. They filed it with the Office of the Clerk of Court (OCC) of the RTC of Muntinlupa City.
• The Erroneous Raffle: The case was raffled to Branch 276, a regular branch, instead of Branch 256, the sole designated Special Commercial Court. Branch 276 issued a TRO and a writ of preliminary injunction.
• The Motion to Dismiss: Respondents filed a motion to dismiss based on lack of jurisdiction, arguing the case was an intra-corporate dispute cognizable only by the Special Commercial Court.
• The Dismissal: Branch 276 granted the motion and dismissed the case. It relied on Calleja v. Panday, holding that as a non-designated branch, it had no jurisdiction and no authority to order the transfer to Branch 256.

• The erroneous raffle was beyond their control; they filed in the correct official station.
• Dismissal prejudices them as their filing fees (P235,825.00) would go to waste.
• Under RA 8799, RTCs have jurisdiction over intra-corporate disputes; the SC merely designates specific branches to hear them.
• The proper remedy is transfer or re-raffle to the proper branch, not dismissal.

• The case involves an intra-corporate dispute falling under the exclusive original jurisdiction of RTCs designated as Special Commercial Courts.
• Branch 276 is not a designated Special Commercial Court and therefore lacks jurisdiction.
• Under Calleja v. Panday, a non-designated branch cannot order the transfer of the case; dismissal is the only proper action.

• Procedural Issues: Whether a regular RTC branch should dismiss a commercial case erroneously raffled to it, or order its transfer to the designated Special Commercial Court.
• Substantive Issues: Whether the SC's designation of Special Commercial Courts confers subject matter jurisdiction or merely regulates the exercise of jurisdiction.

• Procedural: The SC ruled that the regular branch should not dismiss the case. It should refer the case to the Executive Judge for re-docketing as a commercial case, who will then assign it to the designated Special Commercial Court. Dismissal is improper because the RTC (as an entity) already acquired jurisdiction upon filing with the OCC.
• Substantive: The SC ruled that RA 8799 transferred jurisdiction to "Courts of general jurisdiction or the appropriate Regional Trial Court." The word "or" is expository, meaning RTCs are the courts of general jurisdiction. The proviso allowing the SC to "designate the Regional Trial Court branches that shall exercise jurisdiction" refers to the exercise of jurisdiction (a procedural matter), not the conferment of subject matter jurisdiction (a substantive matter). The designation of Special Commercial Courts is a procedural tool for efficiency under the SC's administrative supervisory power, not a jurisdictional grant.

• Jurisdiction over the Subject Matter vs. Exercise of Jurisdiction — Jurisdiction over the subject matter is conferred by law (substantive), whereas the exercise of jurisdiction is governed by the Rules of Court or SC orders (procedural). The SC's designation of Special Commercial Courts is an incident related to the exercise of jurisdiction, not the conferment of subject matter jurisdiction.
• Nature of Special Commercial Courts — Special Commercial Courts are not courts of limited jurisdiction. They are regular RTC branches directed to focus on specific cases for efficiency. They retain the RTC's general jurisdiction over ordinary civil cases.
• Guidelines for Erroneous Raffling — The SC established the following multi-part procedure:
• Commercial case wrongly raffled to a regular branch: 1.1. If the RTC has only one designated SCC: Refer to Executive Judge -> Re-docket as commercial case -> Assign to the sole SCC. 1.2. If the RTC has multiple designated SCCs: Refer to Executive Judge -> Re-docket as commercial case -> Raffle among the SCCs. 1.3. If the RTC has no designated SCC: Refer to the nearest RTC with an SCC within the region -> Re-docket -> Assign to sole SCC or raffle among multiple SCCs.
• Ordinary civil case wrongly raffled to an SCC: Refer to Executive Judge -> Re-docket as ordinary civil case -> Raffle to all branches (including SCCs, which retain general jurisdiction).
• Docket Fees: Account for differences; credit payments; refund excess.
• Caption Requirement: All initiatory pleadings must state the action's nature in both the caption and the body. Failure may result in dismissal without prejudice to re-filing (prospective application).

• Item 5.2, Section 5, RA 8799 (Securities Regulation Code) — Transferred SEC jurisdiction over intra-corporate disputes to "Courts of general jurisdiction or the appropriate Regional Trial Court" with a proviso that the SC may designate branches to exercise jurisdiction. The SC interpreted "or" as expository/equivalent, meaning RTCs are the courts of general jurisdiction.
• Section 19(6), BP 129 (Judiciary Reorganization Act of 1980) — Grants RTCs exclusive original jurisdiction over all cases not within the exclusive jurisdiction of any other court (general jurisdiction).
• Section 6, Article VIII, 1987 Constitution — Grants the SC administrative supervision over all courts (basis for designating SCCs).
• Section 2, Article VIII, 1987 Constitution — Vests in Congress the power to define, prescribe, and apportion jurisdiction (the SC cannot enlarge/diminish jurisdiction).
• A.M. No. 03-03-03-SC — Consolidated IP and commercial courts into Special Commercial Courts. Required filing in the OCC of the official station of the designated SCC.

• Perez, J. (Dissenting) — Argued that RA 8799 transferred jurisdiction specifically to the "appropriate RTC" as designated by the SC. The proviso in Sec 5.2 is a definition of conferred jurisdiction, not just a procedural rule. Non-designated branches lack jurisdiction and must dismiss. Petitioners should suffer the consequences of mis-captioning their complaint, which caused the erroneous raffle.