Sy v. Mina
REITERATIONFacts
The Antecedents: Private respondent M. Chuakay & Sons Rice Mill, Inc. filed a complaint against petitioner Mercedes Sy for the recovery of P8,560.00, representing the value of 180 cavans of rice purchased by Sy. The purchase was made in Quezon City, but the Sales Invoice Receipt issued to Sy contained a stipulation that "in the event of default or non-payment buyer agrees further to the jurisdiction of Cabatuan, Isabela Courts." Sy paid with a post-dated check which was dishonored, and a subsequent check also bounced. Private respondent prayed for a writ of preliminary attachment. Procedural History: Respondent Judge Dominador C. Mina issued a writ of attachment. Petitioner Sy filed a Motion to Dismiss and to Discharge the Writ of Attachment, arguing improper venue as the transaction occurred in Quezon City where she resides, and a criminal case for estafa was filed there. Private respondent countered that Sy waived her right to venue through the stipulation in the Sales Invoice Receipt. The Municipal Court denied the motion to dismiss and discharge the writ. Petitioner's motion for reconsideration was also denied. The Petition: Petitioner filed a petition for prohibition and certiorari with preliminary injunction to set aside the orders of the Municipal Court, raising the issues of whether the Municipal Court of Cabatuan, Isabela was the proper venue and whether the sales invoice receipt could change the venue.
Issue(s)
Whether or not the Municipal Court of Cabatuan, Isabela is the proper venue of respondent Chaukay's Civil Case No. 298 against the petitioner Mercedes Sy, considering the unsigned sales invoice receipt and Section 3, Rule 4 of the Revised Rules of Court.
Ruling
The petition is devoid of merit. The Municipal Court of Cabatuan, Isabela is the proper venue. The writ of preliminary injunction is lifted, and the case is remanded to the lower court for hearing on the merits.
Ratio Decidendi
On the issue of venue and the validity of the stipulation in the Sales Invoice Receipt: The Court held that the pivotal issue is whether the Sales Invoice Receipt stipulation is determinative of the venue. The stipulation stated that the buyer agrees to the jurisdiction of Cabatuan, Isabela Courts in case of default or non-payment. Petitioner argued that an unsigned invoice cannot be a "written agreement" as required by Section 3, Rule 4 of the Revised Rules of Court, which necessitates signatures to show a meeting of the minds. However, the Supreme Court, citing previous rulings, found this argument unmeritorious. The Court reiterated the principle established in Pan Pacific Company (Phil.) vs. Advertising Corporation (23 SCRA 991), where it was held that the vendee's acceptance of goods and their use constitute implied conformity to the terms of the invoices, making the vendee bound thereby. Furthermore, in Naga Development v. Court of Appeals (41 SCRA 106), the Court categorically stated that a buyer's failure to object to invoices containing such clauses is deemed an implied acceptance of those conditions. Therefore, despite the absence of a signature on the sales invoice receipt, the petitioner's actions, such as accepting the goods and failing to object to the terms, constituted an implied agreement to the venue stipulation, making the Municipal Court of Cabatuan, Isabela the proper venue.
Main Doctrine
A buyer's acceptance of goods and use thereof, or failure to object to terms in invoices, constitutes implied conformity and acceptance of such terms, including stipulations on venue.