GR 123910; (April, 1999) (Digest)
G.R. No. 123910 . April 5, 1999.
GODOFREDO UNILONGO, ET AL. and STO. NIÑO DE CUL DE SAC HOMEOWNERS’ ASSOCIATION, INC., petitioners, vs. THE HON. COURT OF APPEALS, HON. RUBEN A. MENDIOLA, BIENVENIDO R. DINO, ET AL., and STO. NIÑO DE CUL DE SAC NEIGHBORHOOD ASSOCIATION, INC., and JULIAN GO, respondents.
FACTS
The Sto. Niño de Cul de Sac Neighborhood Association, Inc. (SNSNAI) was incorporated by petitioners (the Unilongo group) with the Securities and Exchange Commission (SEC) in 1989. After years without elections, private respondents (the Diño group) sought intervention, leading to an election on May 5, 1991, where the Diño group won. Subsequently, the Unilongo group established the Sto. Niño de Cul de Sac Homeowners Association, Inc. (CDSHA) and registered it with the Home Insurance Guarantee Corporation (HIGC). The CDSHA then filed a complaint for injunction and damages against the Diño group with the HIGC (HIGC Case No. 155).
In response, the Diño group filed a Complaint for Quo Warranto with Damages against the Unilongo group before the Regional Trial Court (RTC) of Makati. They alleged that by forming CDSHA, the Unilongo group was unlawfully usurping the offices and functions of the duly elected SNSNAI board. The petitioners moved to dismiss the RTC case, arguing that jurisdiction over the intra-corporate dispute lay with the HIGC, not the ordinary courts. The RTC denied the motion, a decision affirmed by the Court of Appeals, prompting this petition for certiorari.
ISSUE
Whether the Regional Trial Court or the Home Insurance and Guarantee Corporation has jurisdiction over the quo warranto action concerning the rightful officers of the homeowners association.
RULING
The Supreme Court ruled that jurisdiction is vested in the Regional Trial Court. The action filed by the Diño group was a quo warranto proceeding under Rule 66 of the Rules of Court, which is within the original jurisdiction of the RTC pursuant to Batas Pambansa Blg. 129. The core relief sought was a declaration of the rightful holders of corporate offices in SNSNAI and the ouster of the usurpers, which is the precise function of a quo warranto action.
The Court clarified that while the HIGC has adjudicatory power over homeowners associations registered with it under Presidential Decree No. 957, its jurisdiction is not exclusive. The dispute here fundamentally involved a controversy over corporate office within SNSNAI, a corporation registered with the SEC, not the HIGC. The creation of CDSHA with the HIGC was alleged to be a scheme to perpetuate control, but the primary subject of the suit remained the offices in the SEC-registered SNSNAI. Therefore, the RTC correctly took cognizance of the quo warranto case, as it did not constitute an intra-corporate dispute falling under the exclusive jurisdiction of the HIGC at that time. The petition was denied.