Wise Holdings v. Francisco P. Garcia

Summary

Wise Holdings, along with individual petitioners Aliño and Campa, filed suit claiming beneficial ownership of shares in Sunrich Manufacturing Corporation that were registered in respondents' names as trustees/nominees. The lower courts dismissed the complaints as intra-corporate controversies filed in wrong venue. The Supreme Court reversed, ruling this was an ordinary civil case for reconveyance based on implied trust under the Civil Code, not an intra-corporate dispute. The Court applied both relationship and nature of controversy tests, finding no registered corporate relationship between petitioners and Sunrich, and that the action seeks enforcement of trust obligations under Civil Code rather than Corporation Code rights. The case was remanded for proper handling as a civil case with jurisdiction in Mandaluyong City.