Manila Railroad Co. v. Hilario
REITERATIONFacts
The Antecedents: A civil case for damages was filed against Manila Railroad Company (MRC) and its train driver, Andres Garcia, for personal injuries sustained by Emilia de la Cruz due to a collision between an MRC train and a truck. Emilia de la Cruz was the wife and mother of the plaintiffs. Procedural History: The defendants, MRC and Garcia, filed a motion to dismiss the complaint on the ground of improper venue. They argued that the plaintiffs resided in Nueva Ecija, MRC's main office was in Manila, and the other defendant also resided in Manila, thus Tarlac was not the proper venue. The Petition: MRC and Garcia filed a petition for certiorari and prohibition with the Supreme Court, alleging lack of jurisdiction and/or abuse of discretion by the respondent judge. They contended that the respondent judge erred in denying their motion to dismiss.
Issue(s)
Whether the respondent judge committed an abuse of discretion or acted without jurisdiction in denying the motion to dismiss based on improper venue, despite allegations of a plaintiff's residence in Tarlac. Whether the venue was properly laid in the Court of First Instance of Tarlac.
Ruling
The petition for certiorari and prohibition is dismissed. The Court held that the venue was properly laid in Tarlac based on the allegation of one of the plaintiffs' residence therein, and the respondent judge did not abuse his discretion in denying the motion to dismiss.
Ratio Decidendi
On Issue 1: The Court held that the respondent judge did not commit an abuse of discretion in denying the motion to dismiss. The Rules of Court allow a case to be filed in the province where any of the plaintiffs reside. The amended complaint alleged that Fortunato Pano, one of the plaintiffs, was a resident of Paniqui, Tarlac. This allegation, even if disputed by the defendants, was sufficient at the preliminary stage to establish venue. The judge was not prohibited from taking cognizance of the litigation based on this affirmative allegation. The veracity of the residence claim is a matter to be proven during the trial, not a ground for dismissal at this juncture. The certificates submitted by the petitioners questioning Fortunato Pano's residence should be presented as evidence to the trial court during the appropriate stage of the proceedings. On Issue 2: The venue was properly laid in the Court of First Instance of Tarlac. The Court reiterated that the question of venue is distinct from jurisdiction. For purposes of venue, an allegation of residence by a plaintiff within the court's territorial jurisdiction is sufficient to establish venue. The respondent judge correctly accepted this allegation prima facie for the purpose of denying the motion to dismiss. The judge's remarks, while not entirely acceptable in all aspects, indicated a consideration of the purpose of venue rules, which is to provide convenience to the plaintiff and facilitate the proceedings, such as ocular inspections, especially in cases involving a railroad company operating within various localities.
Main Doctrine
The venue of an action is properly laid if there is an allegation that at least one of the plaintiffs resides within the territorial jurisdiction of the court. Such an allegation, even if disputed by the defendants, is sufficient at the outset to prevent a prohibition against the court taking cognizance of the case. The veracity of the residence claim is a matter of proof to be presented during the trial, not a ground for dismissal at the preliminary stage.