Arquero v. Flojo
REITERATIONFacts
1. The Antecedents: The petitioner, Bernoli P. Arquero, entered into a contract with Radio Communication of the Philippines, Inc. (RCPI) for the transmission of a telegram. The contract stipulated that RCPI would not be liable for damages except for a refund of tolls, and that any complaint must be brought within three months and exclusively in the courts of Quezon City. The petitioner sent a telegram to Atty. Eleazar S. Calasan, who was subsequently required to pay delivery charges. Later, at a social gathering, Atty. Calasan publicly berated the petitioner for the telegram, allegedly causing damage to the petitioner's reputation. 2. Procedural History: The petitioner filed an action for damages against RCPI before the Regional Trial Court (RTC) of Aparri, Cagayan. RCPI moved to dismiss the case, asserting that the venue was improperly laid, as the contract explicitly designated Quezon City as the sole venue for any legal action. The RTC granted RCPI's motion and dismissed the case. The petitioner's motion for reconsideration was subsequently denied. 3. The Petition: The petitioner seeks review of the RTC's dismissal, arguing that the venue stipulation in the RCPI telegram form is void and unenforceable, citing Sweet Lines, Inc. v. Bernardo Teves, et al., which held that contracts of adhesion with such stipulations are contrary to public policy. The petitioner contends he had no part in drafting the contract terms. The Supreme Court, however, distinguishes this case from Sweet Lines, noting that the venue stipulation was clearly printed and that the petitioner, being a lawyer and a mayor, must be deemed to have notice and assented to the condition by signing the contract.
Issue(s)
Whether the venue stipulation in the RCPI telegram form limiting the venue of actions to the courts of Quezon City alone is valid and enforceable against a petitioner who is a lawyer and a municipal mayor.
Ruling
The petition is dismissed for lack of merit. The stipulation on venue is valid and enforceable.
Ratio Decidendi
On Issue 1: The Court ruled that the venue stipulation is valid and enforceable. Applying the principles in Bautista v. de Borja and Central Azucarera de Tarlac v. De Leon, the Court held that Section 3, Rule 4 of the Revised Rules of Court explicitly allows parties to change the venue of an action by written agreement. The Court emphasized that venue is a personal privilege that can be waived, and such a waiver is effective provided it is not contrary to public policy or prejudicial to third parties. In this specific case, the Court distinguished the ruling in Sweet Lines, Inc. v. Teves, noting that the circumstances there involved a monopoly in inter-island shipping and passengers who often lacked the time or literacy to review tickets. Conversely, the petitioner here is a lawyer and a Municipal Mayor; his educational attainment and professional status charge him with notice of the conditions printed clearly on the telegram form. By affixing his signature, the petitioner signified his assent to the terms, including the limitation of venue to Quezon City. Therefore, the contract of adhesion doctrine does not apply to invalidate the stipulation when the party has the capacity and opportunity to understand the terms.
Main Doctrine
A stipulation on venue in a contract of adhesion, such as a telegram transmission form, is valid and enforceable if the condition is clearly printed and the party affixing their signature is presumed to have notice and assented to it, especially when the party is educated and not in a position of disadvantage.