Villanueva v. Mosqueda
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns an ejectment suit filed by the heirs of Basilio Bonifacio against Eduardo Villanueva. The parties had entered into a supplementary lease agreement for a house in Tondo, Manila. This agreement contained a stipulation regarding venue: if the lessor violated the contract, suit could be filed in Manila, and if the lessee violated it, suit could be filed in Masantol, Pampanga, where the lessor resided. Villanueva, the lessee, resided in Tondo, Manila. 2. Procedural History: The heirs of Bonifacio initiated an ejectment suit against Villanueva in the municipal court of Masantol, Pampanga. Villanueva moved to dismiss, arguing that the venue was improperly laid in Masantol and should have been Manila, where the property is located, contending the venue stipulation was void. The municipal court denied this motion. Villanueva then filed a petition for certiorari in the Court of First Instance of Pampanga, challenging the denial. The Court of First Instance dismissed his petition, ruling that the venue was properly laid in Masantol due to a valid waiver of legal venue by the parties. 3. The Petition: Eduardo Villanueva filed the instant petition for certiorari with the Supreme Court, assailing the decision of the Court of First Instance. He argued that the venue stipulation in the lease agreement was void and that the ejectment suit should have been filed in Manila. The Supreme Court considered whether the venue stipulation was valid and whether the municipal court of Masantol had jurisdiction. The Court ultimately held that the venue stipulation was valid and enforceable, distinguishing it from cases where venue is merely permissive. The petition was dismissed, affirming the lower court's decision.
Issue(s)
Whether the stipulation in the lease agreement regarding the venue of an ejectment suit is valid. Whether the municipal court of Masantol had jurisdiction over the ejectment suit.
Ruling
The petition is dismissed. The decision of the lower court is affirmed.
Ratio Decidendi
On Whether the stipulation in the lease agreement regarding the venue of an ejectment suit is valid: The Court held that the petition has no merit. It is incontrovertible that the municipal court of Masantol, like other inferior courts, has exclusive original jurisdiction to entertain ejectment suits. The rule in Section 1(a), Rule 4 of the Rules of Court, which states that forcible entry and detainer actions regarding real property shall be brought in the municipality or city where the subject matter is situated, does not refer to jurisdiction over the subject matter but only to the place where the suit may be brought. Section 3 of Rule 4 explicitly provides that "by written agreement of the parties the venue of an action may be changed or transferred from one province to another." In this case, such an agreement was formalized between the lessor and the lessee. The agreement is valid, binding, and enforceable. The Court distinguished this case from one where the stipulation on venue is merely permissive, as opposed to mandatory, and thus does not constitute a waiver of the right to choose the venue provided by law. On Whether the municipal court of Masantol had jurisdiction over the ejectment suit: The Court affirmed the ruling of the lower court. The municipal court of Masantol, as an inferior court, possesses the exclusive original jurisdiction to hear and decide ejectment cases. The stipulation in the lease agreement between the lessor and the lessee, wherein they agreed that an action could be filed in Masantol, Pampanga, constituted a valid waiver of the legal venue. This waiver is permissible under Section 3 of Rule 4 of the Rules of Court, which allows parties to change or transfer the venue of an action by written agreement. Therefore, the municipal court of Masantol correctly assumed jurisdiction over the ejectment suit based on the parties' express agreement.
Main Doctrine
The parties to a contract may validly agree in writing to change or transfer the venue of an action arising from said contract, provided such agreement does not contravene the rules on jurisdiction.