a. Special Commercial Courts

Special Commercial Courts

Concept

A Special Commercial Court (SCC) is a designated branch of a Regional Trial Court (RTC). Its designation governs the assignment and handling of commercial cases; it does not create a separate court or strip the branch of its character as a court of general jurisdiction. (Concorde Condominium, Inc. v. Morales, G.R. No. 203678, 17 February 2016)¹ (Majestic Plus Holding International, Inc. v. Corporation, G.R. No. 201017, 5 December 2016)²

Governing provisions

The Judiciary Reorganization Act of 1980, as amended by Republic Act No. 7691, provides for the RTC’s exclusive original jurisdiction over specified civil actions, including actions whose subject is incapable of pecuniary estimation and cases not within the exclusive jurisdiction of another court, tribunal, person, or body exercising judicial or quasi-judicial functions. SCC designation must be understood against that grant of jurisdiction. (Judiciary Reorganization Act of 1980, as amended by Rep. Act No. 7691)³ (Concorde Condominium, Inc. v. Morales)¹

Requisites / Rules

• Determine subject-matter jurisdiction from the allegations of the complaint. The complaint’s averments and the relief sought identify the nature of the action; jurisdiction, once vested, remains even if the plaintiff cannot recover on every claim. (Concorde Condominium, Inc. v. Morales)¹ (Ku v. Rcbc Securities, Inc., G.R. No. 219491, 17 October 2018)⁴
• For an alleged intra-corporate controversy, apply both the relationship test and the nature of the controversy test. (Ku v. Rcbc Securities, Inc.)⁴
• A designated SCC must try and decide commercial cases within its jurisdiction. If a commercial case is wrongly raffled to a regular branch and the RTC has only one designated SCC, refer it to the Executive Judge for re-docketing and assignment to that SCC. (Gonzales v. Land, G.R. No. 202664, 20 November 2015)⁵

Distinctions

Subject-matter jurisdiction is conferred by law. By contrast, whether an RTC branch acts in its general or limited jurisdiction, and whether it is designated as an SCC, concerns procedure or the exercise of jurisdiction. Neither distinction changes the branch’s acquisition of subject-matter jurisdiction. (Ku v. Rcbc Securities, Inc.)⁴ (Gonzales v. Land)⁵ (Concorde Condominium, Inc. v. Morales)¹

Key doctrines

An SCC may hear ordinary civil cases, including an action for injunction; it cannot dismiss such a case merely because the branch carries an SCC designation. Likewise, designation does not deprive an RTC branch of jurisdiction to hear an intra-corporate dispute. (Concorde Condominium, Inc. v. Morales)¹ (Majestic Plus Holding International, Inc. v. Corporation)²

Exceptions

The SCC designation does not override limits on judicial relief. Courts other than the Supreme Court are prohibited from issuing temporary restraining orders, preliminary injunctions, or preliminary mandatory injunctions against the government or persons acting under its direction under the prohibition identified in Office of the Court Administrator v. Villarosa. (Office of the Court Administrator v. Villarosa, A.M. No. 19-11-268-, 28 January 2020)⁶

Bar tip

Separate two questions: Does the RTC have subject-matter jurisdiction under law, and was the case assigned to the proper branch? A mistaken raffle of a commercial case calls for proper re-docketing and assignment, not a conclusion that SCC designation itself creates or removes jurisdiction. (Ku v. Rcbc Securities, Inc.)⁴ (Gonzales v. Land)⁵