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Jurisdiction; Doctrine of Non-Interference

Go v. Clerk of Court
Facts: Bacolod RTC issued a writ of execution over a house and lot registered in the name of Mr.
Looyuko. Mr. Go filed a complaint for injunction with a prayer for writ of preliminary injunction to enjoin
the sheriffs from enforcing of the writ of exec. before the Pasig RTC. RTC Pasig approved.
Issue: WON Pasig RTC has the right to interfere with the order of the Bacolod RTC, a co-equal court
Ruling: NO. No court has the power to interfere by injunction with the judgments or orders of another
court of concurrent jurisdiction having the power to grant the relief sought by injunction. This doctrine
of non-interference is premised on the principle that a judgment of a court of competent jurisdiction
may not be opened, modified or vacated by any court of concurrent jurisdiction. Since the Bacolod
RTC had already acquired jurisdiction over the collection suit and rendered judgment in relation
thereto, it retained jurisdiction to the exclusion of all other coordinate courts over its judgment,
including all incidents relative to the control and conduct of its ministerial officers, namely the sheriffs.
Jurisdiction; SC, CA, RTC, MTC
Reyes v. RTC Makati [Note: Not reported; According to Maam: intra-corporate controversy is
lodged on Corporation Law subject]
Facts: Rodrigo a shareholder of Zenith Corp. filed a case against his brother Oscar before Securities
and Exchange Commission to determine the shares of stock of their deceased mother in Zenith that
were fraudulently appropriated by Oscar for himself. He also prayed that their just and respective
shares should now be delivered to his brothers and sisters. R.A. No. 8799 transferred to the RTC
designated as a special commercial court, SECs exclusive and original jurisdiction over cases
enumerated in Section 5 of Presidential Decree (P.D.) No. 902-A (including intra-corporate
controversy/ICC). Rodrigo alleged that the present case is an ICC
Issue: WON RTC as a special commercial court has jurisdiction over the case
Ruling: NO. For it to be an intra-corporate controversy, it requires that the dispute among the parties
be intrinsically connected with the regulation of the corporation. But what is material in resolving the
issues of this case under the allegations of the complaint is Rodrigos interest as an heir since the
subject matter of the present controversy centers on the shares of stocks belonging to their mother,
not on Rodrigos personally-owned shares nor on his personality as shareholder owning these shares.
The RTC sitting as special commercial court has no jurisdiction to hear the complaint since what
is involved is the determination and distribution of successional rights to the shareholdings of the
mother. The controversy it presents is purely civil rather than corporate.

Rule 1; Section 6
Cobarrubias vs. CA [Note: not reported]
Facts: CA granted Mr. Cobarrubias MR filed before it. In its Resolution, CA directed him to implead
the People of the Philippines as respondent. Eventually, CA dismissed Cobarubbias petition for his
failure to comply with said resolution holding that manifest delay is a ground for dismissal under
Section 8, Rule 65. He then filed another MR and a Motion to Admit Amended Petition (now
impleading the People), which the CA dismissed.
Issue: WON the CA erred in dismissing the petition on the ground of technicality
Ruling: YES. SC applied Sec. 6, Rule 1. In several cases, the Court has ruled against the dismissal
of petitions or appeals based solely on technicalities especially when there was subsequent
substantial compliance with the formal requirements. In this case, the Court finds the Cobarrubias
failure to implead the People of the Philippines as respondent not so grave as to warrant dismissal of
the petition. After all, he rectified his error by moving for reconsideration and filing an Amended

Petition, impleading the People of the Philippines as respondent. Technicalities may be set
aside when the strict and rigid application of the rules will frustrate rather than promote justice.

Rule 3; Section 2
Manese v. Velasco
Facts: Velasco was granted by the government a property which is a foreshore land. Manese filed a
Complaint for Annulment of Title against Velasco on the subject property.
Issue: WON Manese is a real party in interest with authority to file a complaint for annulment of title of
foreshore land
Ruling: NO. The subject matter of controversy is foreshore land which is a part of the public domain.
Section 101 of Commonwealth Act No. 141 provides that in all actions for the reversion to the
Government of lands of the public domain or improvements thereon, the Republic of the Philippines is
the real party in interest. The action shall be instituted by the Solicitor General or the officer acting in
his stead, in behalf of the Republic of the Philippines. (Commentary from Maam: Manese, a private
person does not stand injured nor benefitted in this case since he cannot have any interest over the
foreshore land.)