G.R. No. 203678 February 17, 2016
CONCORDE CONDOMINIUM, INC., by itself and comprising the Unit Owners of Concorde Condominium Building, Petitioner, vs. AUGUSTO H. BACULIO; NEW PPI CORPORATION; ASIAN SECURITY and INVESTIGATION AGENCY and its security guards; ENGR. NELSON B. MORALES, in his capacity as Building Official of the Makati City Engineering Department; SUPT. RICARDO C. PERDIGON, in his capacity as City Fire Marshal of the Makati City Fire Station; F/C SUPT. SANTIAGO E. LAGUNA, in his capacity as Regional Director of the Bureau of Fire Protection-NCR, and any and all persons acting with or under them, Respondents.

FACTS

Petitioner Concorde Condominium, Inc., representing the unit owners, filed a Petition for Injunction with Damages in the Makati RTC, a court designated as a Special Commercial Court. The petition sought to enjoin respondents Baculio and New PPI Corporation from misrepresenting ownership of the condominium land and building and from pursuing demolition; to prevent a security agency from deploying guards; and to restrain certain government officials from acting on Baculio’s letters regarding permits and fire safety. The RTC initially issued an order directing inspections and setting deadlines for repairs.
Respondents Baculio and New PPI Corporation filed a Motion to Dismiss, arguing the RTC, acting as a Special Commercial Court, lacked jurisdiction. They contended the petition did not involve an intra-corporate controversy under P.D. No. 902-A but sought to restrain or compel specific acts of individuals and officials. The RTC granted the motion and dismissed the case for lack of jurisdiction, prompting petitioner’s appeal to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Regional Trial Court, acting as a Special Commercial Court, has jurisdiction over the Petition for Injunction filed by the condominium corporation.

RULING

No, the Special Commercial Court correctly dismissed the case for lack of jurisdiction. The Supreme Court affirmed the dismissal. The legal logic hinges on the jurisdiction of Special Commercial Courts, which is limited to cases originally cognizable by the Securities and Exchange Commission (SEC) under P.D. No. 902-A, specifically intra-corporate controversies. Jurisdiction over such controversies is determined using a combination of the relationship test and the nature of the controversy test.
Applying these tests, the petition failed to qualify as an intra-corporate controversy. The primary reliefs sought were to enjoin acts of misrepresentation, security deployment, and actions by government building and fire safety officials. The core issues pertained to property ownership, threats of demolition, and administrative orders from government agencies, not to the internal governance of the condominium corporation or the rights and obligations of its members under the Corporation Code. The involvement of the condominium corporation as the petitioner did not automatically convert the case into an intra-corporate dispute. Since the subject matter of the injunction fell outside the exclusive jurisdiction of the Special Commercial Court, the RTC correctly dismissed the petition. The proper recourse for the petitioner was to file the action in a regular court of appropriate jurisdiction.