G.R. No. 95067 July 23, 1992
GERARDO ARANAS and FELINA RAVACIO ARANAS, petitioners, vs. HONORABLE COURT OF APPEALS, ILIGAN CAPITOL COLLEGE, SESENIO ROSALES and LAUREANA ROSALES, respondents.

FACTS

Petitioners Gerardo Aranas and Felina Ravacio Aranas were plaintiffs in Civil Case No. 1276 before the Regional Trial Court (RTC) of Lanao del Norte, Branch I, Iligan City. On August 7, 1975, the RTC rendered a judgment ordering the defendants (herein private respondents Iligan Capitol College, Sesenio Rosales, and Laureana Rosales) to jointly and severally cause the issuance of a certificate of stock corresponding to the petitioners’ cash investment of P5,730.00 and to deliver their unrealized profits/dividends from May 1964. On July 25, 1984, the petitioners filed a motion to compel respondent Iligan Capitol College to submit corporate records for examination to enforce the judgment. The RTC issued orders and writs of execution, but private respondents refused to comply. On April 24, 1989, the RTC issued another order and alias writ of execution. Private respondents then filed a motion for reconsideration, claiming the case involved an intra-corporate dispute cognizable by the Securities and Exchange Commission (SEC) under Presidential Decree No. 902-A. The RTC maintained its jurisdiction in an order dated June 29, 1989. Private respondents filed a petition for certiorari before the Court of Appeals, which sustained their position. Petitioners now seek review, arguing the matter is simply the execution of a final RTC judgment.

ISSUE

Does the Securities and Exchange Commission (SEC) have jurisdiction over an intra-corporate dispute which occurred prior to, but remained outstanding or unfinished after the promulgation of PD 902-A on March 11, 1976?

RULING

Yes. The Supreme Court affirmed the decision of the Court of Appeals. While the RTC judgment dated August 7, 1975, is final and executory, and its execution generally remains under the issuing court’s jurisdiction, the evident purpose of PD 902-A in investing the SEC with adjudicatory powers over intra-corporate disputes is to promote dispatch and expertise in settling such controversies. This applies regardless of whether the acts giving rise to the litigation occurred before or after PD 902-A’s promulgation. The Court noted that private respondents did not move for transfer to the SEC immediately after March 11, 1976, and thus acquiesced to the RTC proceedings. However, execution and subsequent incidents must be transferred to the SEC’s jurisdiction, as this is the clear intent of PD 902-A. The Supreme Court ordered the SEC to cause execution of the final RTC judgment, including the issuance of the certificate of stock and inspection of corporate books to determine profits and dividends. The case was remanded to the SEC, and the records of Civil Case No. 1276 were ordered transferred thereto.