Atlas Developer & Steel Industries, Inc. v. Sarmiento Enterprises, Inc.
REITERATIONFacts
The Antecedents: Respondent Sarmiento Enterprises, Inc. filed a complaint for collection of P8,076.00 representing the cost of steel bars and MS plates against petitioner Atlas Developer & Steel Industries, Inc. in the Court of First Instance of Pasig, Metro Manila. Procedural History: Petitioner filed a motion to dismiss on the ground of improper venue, citing a stipulation in the sales invoice that stated parties expressly submit to the jurisdiction of the Court of the City of Manila for any legal action to enforce collection. The motion was denied by the RTC. Petitioner's subsequent motions for reconsideration were also denied. The Petition: Petitioner filed a petition for certiorari with the Supreme Court, arguing that the venue was improperly laid in Pasig.
Issue(s)
Whether the stipulation in the sales invoice fixing the venue of legal action is valid and binding. Whether the Regional Trial Court of Pasig had jurisdiction over the collection case, considering the amount involved.
Ruling
The petition for certiorari is granted. The complaint in the Regional Trial Court at Pasig, Metro Manila, is dismissed without prejudice to the plaintiff filing it in the proper inferior court. Costs against the private respondents.
Ratio Decidendi
On the issue of venue stipulation: The Court ruled that the trial judge's interpretation of the stipulation in the sales invoice was overly strict and literal. Although the stipulation mentioned "jurisdiction," the parties' intent was likely to fix the venue only. The Court reiterated that jurisdiction is conferred by law and cannot be altered by mere agreement of the parties. Therefore, the stipulation should be treated as an agreement on venue, not jurisdiction. The Court cited Calimlim, et al. vs. Ramirez, et al. and De Jesus, et al. vs. Garcia, et al. in support of this principle. On the issue of jurisdiction: The Court found that the Regional Trial Court of Pasig erred in taking cognizance of the case. The claim of P8,076.00 did not exceed P20,000.00, which was the minimum jurisdictional limit for a money claim in the Regional Trial Court at the time. According to Sections 19 and 33 of Batas Pambansa Blg. 129 (The Judiciary Reorganization Act of 1980), exclusive original jurisdiction over civil actions where the amount of demand does not exceed P20,000.00 belongs to the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts. The venue of an action in these inferior courts can be specified by the parties through a written agreement, provided the court has jurisdiction by reason of its nature or the amount involved.
Main Doctrine
A stipulation in a sales invoice fixing the venue of legal actions arising from the contract, even if worded as conferring 'jurisdiction,' should be interpreted as an agreement on venue, as jurisdiction is conferred by law and cannot be altered by mere agreement of the parties. Furthermore, the monetary value of the claim must be within the jurisdictional limits of the court where the action is filed.