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Updated 22nd March 2025
Gonzales vs. GJH Land, Inc. (formerly S.J. Land, Inc.)
This case resolves whether a regular branch of the Regional Trial Court (RTC) lacking designation as a Special Commercial Court can dismiss an intra-corporate case for lack of jurisdiction, or should instead transfer it to the designated Special Commercial Court branch.

Primary Holding

A regular RTC branch that receives an intra-corporate case should not dismiss it but should refer it to the Executive Judge for re-docketing as a commercial case and assignment to the designated Special Commercial Court branch.

Background

The case arose from a dispute over corporate shares in S.J. Land, Inc. (later GJH Land, Inc.) where the petitioners claimed full payment of their share subscriptions while the company attempted to sell these allegedly unpaid shares.

History

  • August 4, 2011: Complaint filed with RTC Muntinlupa City

  • August 9, 2011: Temporary restraining order issued

  • August 24, 2011: Preliminary injunction granted

  • April 17, 2012: RTC Branch 276 dismissed the case

  • July 9, 2012: Motion for reconsideration denied

  • November 20, 2015: Supreme Court decision issued

Facts

  • 1. Petitioners claimed they bought shares from S.J. Global, Inc. on February 1, 2010
  • 2. They alleged full payment of subscriptions in S.J. Land, Inc.'s books
  • 3. On July 29, 2011, shares were offered for sale to corporation's stockholders
  • 4. Petitioners filed for injunction with RTC Muntinlupa City
  • 5. Case was raffled to Branch 276 (non-Special Commercial Court)
  • 6. Branch 256 was the designated Special Commercial Court

Arguments of the Petitioners

  • 1. Filing with Clerk of Court was proper procedure
  • 2. Wrong assignment by raffle was beyond their control
  • 3. Paid substantial filing fees (P235,825.00)
  • 4. RTC has jurisdiction under RA 8799
  • 5. Case should be transferred to proper branch rather than dismissed

Arguments of the Respondents

  • 1. Case involves intra-corporate dispute
  • 2. Should be heard by designated Special Commercial Court
  • 3. Branch 276 lacks jurisdiction over subject matter

Issues

  • 1. Case involves intra-corporate dispute
  • 2. Should be heard by designated Special Commercial Court
  • 3. Branch 276 lacks jurisdiction over subject matter

Ruling

  • 1. Supreme Court reversed and set aside the dismissal
  • 2. Held that jurisdiction was properly acquired by RTC Muntinlupa City upon filing
  • 3. Wrong branch assignment is merely procedural matter
  • 4. Branch 276 should have referred case to Executive Judge for re-docketing and assignment to Branch 256
  • 5. Court established detailed guidelines for handling commercial cases wrongly raffled to regular branches

Doctrines

  • 1. Distinction between jurisdiction over subject matter and exercise of jurisdiction
  • 2. Courts of general jurisdiction doctrine for RTCs
  • 3. Administrative supervision power of Supreme Court
  • 4. Statutory construction principles regarding jurisdiction

Precedents Cited

  • 1. Calleja v. Panday (2006): Distinguished from present case as it involved different RTCs
  • 2. Tan v. Bausch & Lomb, Inc.: Used as proper reference for transfer of cases between branches
  • 3. Lozada v. Bracewell: Cited regarding matter of procedure vs jurisdiction

Statutory and Constitutional Provisions

  • 1. Article VIII, Section 2: Congress' power to define court jurisdiction
  • 2. Article VIII, Section 6: Supreme Court's administrative supervision
  • 3. RA 8799 Section 5.2: Transfer of SEC jurisdiction to RTCs
  • 4. BP 129 Section 19(6): RTC as courts of general jurisdiction