Bitmicro Networks v. Gilberto Cunanan

Summary

This Supreme Court case resolved a jurisdictional dispute over whether allegations of tortious interference with corporate contracts constitute a civil matter or an intra-corporate controversy. Petitioner corporations and officers sued respondents Cunanan and Ong for allegedly preventing them from performing corporate functions and causing breach of a Service Agreement. The RTC found it a civil case, but the Court of Appeals reversed, ruling it was an intra-corporate dispute requiring special commercial court jurisdiction. The Supreme Court applied both the relationship test and nature of controversy test, concluding this was purely a civil action for tortious interference under Civil Code Articles 1314 and 2176. The Court emphasized that not all disputes involving corporations and former officers are intra-corporate, and that jurisdiction depends on whether the dispute involves enforcement of correlative rights under the Corporation Code and internal corporate rules. The case was remanded to the RTC for trial on the merits of the tortious interference claims.