Koh v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from a complaint for damages filed by Jose P. Coloma against Francisco T. Koh. Coloma sought P173,000.00, alleging malicious prosecution stemming from a criminal complaint for estafa filed by Koh against Coloma. This criminal complaint arose from a dishonored post-dated check issued by Coloma to Koh as part of a compromise agreement to settle a forcible entry and detainer case concerning a property in Mandaluyong, Rizal. The criminal case was eventually dismissed by the Court of First Instance of Rizal. 2. Procedural History: Coloma filed his complaint for damages in the Court of First Instance (CFI) of Ilocos Norte. Koh moved to dismiss the complaint, arguing it failed to state a cause of action and that venue was improperly laid. The CFI denied Koh's motion to dismiss and a subsequent motion for reconsideration. Koh then filed a petition for certiorari with preliminary injunction with the Court of Appeals (CA), challenging these denials. The CA initially dismissed the petition for failure to attach certified true copies of the orders, but later reconsidered and gave it due course, issuing a writ of preliminary injunction. After the parties submitted their pleadings and memoranda, the CA dismissed Koh's petition for certiorari and dissolved the injunction, finding no grave abuse of discretion by the trial court. 3. The Petition: This petition for certiorari seeks to review and reverse the Court of Appeals' decision. Petitioner Francisco T. Koh argues that the CA erred in upholding the CFI's denial of his motion to dismiss. Specifically, Koh contends that the CA committed grave abuse of discretion by finding that Jose P. Coloma was a resident of San Nicolas, Ilocos Norte, thus making the venue proper, and by concluding that Coloma's complaint stated a sufficient cause of action. Koh asserts that Coloma's actual residence was in the Greater Manila Area, making the filing in Ilocos Norte improper and intended for harassment, and that the basis for the damages claim (the allegedly malicious criminal complaint) was unfounded.
Issue(s)
Whether the Court of Appeals erred in holding that venue was properly laid in the Court of First Instance of Ilocos Norte. Whether the complaint for damages filed by private respondent Jose P. Coloma stated a sufficient cause of action.
Ruling
The Supreme Court reversed the decision of the Court of Appeals, set aside the orders of the Court of First Instance of Ilocos Norte, and dismissed the complaint for improper venue and lack of sufficient cause of action.
Ratio Decidendi
On the issue of venue: The Court held that the venue for personal actions, as governed by Section 2(b) of Rule 4 of the Rules of Court, is determined by where the defendant or any of the defendants resides or may be found, or where the plaintiff or any of the plaintiffs resides, at the election of the plaintiff. The Court emphasized that the term "resides" is crucial, and it is not synonymous with "domicile." While Coloma claimed domicile in San Nicolas, Ilocos Norte, based on his intention to return there, he admitted to residing in Quezon City at the time the action was filed. Furthermore, the motion to dismiss sent to his alleged address in San Nicolas was returned unserved, and his pleadings in numerous other cases consistently stated residences in the Greater Manila Area. The Court found his protestations of domicile in Ilocos Norte to be of no moment, as his actual residence at the time of filing was in Quezon City, making the venue in Ilocos Norte improper. On the issue of sufficient cause of action: The Court found that the complaint for damages lacked a sufficient cause of action. The damages were sought based on an alleged "malicious, baseless, and unfounded criminal complaint" filed by petitioner. However, the underlying criminal complaint for estafa arose from a dishonored check issued by Coloma. The Court noted that the criminal complaint was filed by the Fiscal of Rizal after a preliminary investigation, indicating a prima facie case. The petitioner was merely the offended party and private prosecutor, not the one who filed the complaint in a malicious manner. The dismissal of the criminal case by the CFI of Rizal, even if on technicality or reasonable doubt, did not absolve Coloma from civil liability. Therefore, the Court concluded that the criminal complaint could not be characterized as "malicious, baseless, and unfounded," rendering the subsequent action for damages without basis.
Main Doctrine
The venue for personal actions under Section 2(b) of Rule 4 of the Rules of Court is determined by where the defendant or plaintiff actually resides or may be found, not solely by their declared domicile or intention to return to a place of origin. A complaint for damages based on a criminal prosecution initiated by a fiscal after preliminary investigation, arising from a dishonored check, cannot be considered malicious, baseless, or unfounded, thus lacking sufficient cause of action.