GR 107152; (January, 1995) (Digest)
G.R. No. 107152 . January 25, 1995.
MANUEL M. ALLEJE, petitioner, vs. COURT OF APPEALS, SPORTS HEALTH AND PHYSICAL EDUCATION (SHAPE) CENTRE, INC., and/or ARMIE E. ELMA, Presiding Judge, RTC — Pasig, Br. 153, respondents.
FACTS
Private respondent SHAPE Centre, Inc., a non-stock, non-profit corporation, filed a complaint for injunction and damages with preliminary attachment against its former Executive Vice President, petitioner Manuel M. Alleje, before the Regional Trial Court of Pasig. The complaint alleged that Alleje, during his tenure, committed various acts of misappropriation and fraud to the detriment of the corporation. Specifically, SHAPE accused Alleje of diverting corporate funds for personal use, failing to account for and liquidate substantial cash advances, depositing corporate collections into his personal account, unlawfully removing corporate equipment for use in his own business, and registering a similar service name to mislead the public.
Alleje moved to dismiss the case for lack of jurisdiction, contending that the dispute was an intracorporate controversy falling under the exclusive original jurisdiction of the Securities and Exchange Commission (SEC) pursuant to Presidential Decree No. 902-A. The trial court denied the motion, ruling that the action was essentially for the recovery of assets and properties, not requiring the SEC’s special expertise. The Court of Appeals sustained the trial court’s order, prompting Alleje to elevate the matter to the Supreme Court via petition for review.
ISSUE
Whether the Regional Trial Court has jurisdiction over SHAPE’s complaint for recovery of funds and assets against its former officer, or whether the dispute constitutes an intracorporate controversy within the exclusive jurisdiction of the SEC.
RULING
The Supreme Court granted the petition and ruled that the SEC has jurisdiction. The legal logic hinges on the nature of the allegations as delineated under P.D. 902-A. While the complaint prayed for the recovery of money and assets—matters typically within the purview of regular courts—the foundational accusations were inextricably linked to Alleje’s fiduciary role as a corporate officer. The acts complained of, including the diversion of funds, unauthorized reversals of accounting entries, and misappropriation of corporate assets, were all alleged to have been accomplished by Alleje by employing schemes and fraud by virtue of his position as Executive Vice President.
The Court emphasized that the controversy was not a simple collection suit but one involving allegations of fraud and breach of trust detrimental to the corporation and its members. Such disputes, arising from intra-corporate relations between the corporation and its officers involving fraud, are classified as intracorporate matters under Section 5 of P.D. 902-A. Consequently, the case was beyond the jurisdiction of the Regional Trial Court. The Supreme Court reversed the Court of Appeals, ordered the dismissal of the civil case before the RTC, and directed that the appropriate action be filed with the SEC.
