G.R. No. 203023.June 17, 2015.*PHILIPPINE COMMUNICATIONS SATELLITECORPORATION and PHILCOMSAT HOLDINGSCORPORATION, petitioners, vs. SANDIGANBAYAN, 5thDIVISION and PRESIDENTIAL COMMISSION ONGOOD GOVERNMENT, respondents.Mercantile Law; Corporations; Intra-corporate Controversies; Todetermine if a case involves an intra-corporate controversy, thecourts have applied two (2) tests: the relationship test and the natureof the controversy test.·To determine if a case involves an intra-corporate controversy, the courts have applied two tests: therelationship test and the nature of the controversy test. Under therelationship test, the existence of any of the following relationshipsmakes the conflict intra-corporate: (1) between the corporation,partnership or association and the public; (2) between thecorporation, partnership or association and the State insofar as itsfranchise, permit or license to operate is concerned; (3) between thecorporation, partnership or association and its stockholders,partners, members or officers; and (4) among the stockholders,partners or associates themselves. On the other hand, the nature ofthe controversy testdictates that „the controversy must not only berooted in the existence of an intra-corporate relationship, but mustas well pertain to the enforcement of the partiesÊ correlative rightsand obligations under the Corporation Code and the internal andintra-corporate regulatory rules of the corporation.‰ A combinedapplication of the relationship testand the nature of the controversytest has become the norm in determining whether a case is an intra-corporate controversy, to be „heard and decided by the [b]ranches ofthe RTC specifically designated by the Court to try and decide suchcases.‰Same; Same; Same; Regional Trial Courts; Section 5 ofPresidential Decree (PD) No. 902-A conferred original and exclusivejurisdiction over intra-corporate disputes on the Securities andExchange Commission (SEC). However, Section 5.2 of Republic Act(RA) No. 8799, transferred the jurisdiction over such cases to courts
of general_______________* SECOND DIVISION.243VOL. 759, JUNE 17, 2015243Philippine Communications Satellite Corporation vs.Sandiganbayan, 5th Divisionjurisdiction, or the appropriate Regional Trial Court (RTC).·As such, it is clear that the jurisdiction lies with the regular courtsand not with the Sandiganbayan. Section 5 of Presidential DecreeNo. 902-A conferred original and exclusive jurisdiction over intra-corporate disputes on the SEC. However, Section 5.2 of R.A. 8799,transferred the jurisdiction over such cases to courts of generaljurisdiction, or the appropriate RTC. Petitioners, however, furtherargue that the case must be decided by the Sandiganbayanbecausethe RTC is coequal to the PCGG and therefore would have noauthority to issue an order to the latter.