Fernandez v. International Corporate Bank
REITERATIONFacts
The Antecedents: Petitioners purchased a Nissan Sentra Sedan through a financing scheme with International Corporate Bank (now Union Bank of the Philippines), executing a chattel mortgage on November 10, 1993. The principal amount financed was P344,500.00, with a total payment of P553,944.00 over 48 monthly installments. Procedural History: The respondent bank filed a complaint for a sum of money with replevin before the Metropolitan Trial Court (MTC) of Pasay City, Branch 44, seeking to recover the vehicle. Petitioners contested the jurisdiction of the MTC, arguing that the amount involved (P553,944.00) exceeded its jurisdictional limit, and also objected to the venue. The MTC denied their Motion to Dismiss and Motion for Reconsideration. The MTC noted that the complaint sought to recover P190,635.00, which was within its jurisdiction, and that the promissory note contained a stipulation on venue. The MTC also stated that petitioners failed to post a re-delivery bond within five days of the seizure of the vehicle. The Petition: Petitioners filed a suit for certiorari and prohibition with the Court of Appeals (CA) praying for the redelivery of the vehicle and the declaration of nullity of the Writ of Replevin. The CA dismissed their petition, upholding the MTC's jurisdiction and the validity of the writ's enforcement. Petitioners now seek review of the CA's decision.
Issue(s)
Whether a Writ of Replevin issued by the Metropolitan Trial Court of Pasay City may be enforced outside the territorial confines of Pasay City. Whether the Metropolitan Trial Court of Pasay City had jurisdiction over the complaint filed by the respondent bank. Whether the petitioners were entitled to the redelivery of the subject vehicle.
Ruling
The petition is denied, and the assailed decision of the Court of Appeals is affirmed. Costs against petitioners.
Ratio Decidendi
On the territorial enforcement of the Writ of Replevin: The Court held that a writ of replevin issued by a Metropolitan Trial Court (MTC) may be served and enforced anywhere in the Philippines. This is based on the Supreme Court's Resolution en banc dated January 11, 1983, which provides that all processes, except for those specifically enumerated (like writs of certiorari, prohibition, mandamus, quo warranto, habeas corpus, and injunction issued by a Regional Trial Court), may be served anywhere in the Philippines. The writ of replevin in this case does not fall under the exceptions, thus it can be enforced nationwide. The Court distinguished between a court's jurisdiction to hear and decide a case and its power to issue and enforce writs and processes pursuant to that jurisdiction. On the MTC's jurisdiction over the complaint: The Court affirmed that the MTC had jurisdiction over the complaint. The petitioners' argument that the value of the seized property exceeded the jurisdictional limit was dismissed. The Court clarified that the jurisdiction of the court is determined by the amount of the claim alleged in the complaint, not by the value of the chattel seized in ancillary proceedings. In this case, the principal claim in the complaint was P190,635.90, which was well within the P200,000 jurisdictional limit of the MTC at the time. The value of the vehicle, while potentially higher, was merely collateral to secure the loan. On the entitlement to redelivery of the subject vehicle: The Court found that the petitioners were not entitled to the redelivery of the vehicle because they failed to comply with the requirements for redelivery under the Rules of Court. Specifically, they failed to post a re-delivery bond within the prescribed five-day period from the seizure of the vehicle. The amount they offered via a Manager's Check (P69,168.00) was insufficient to cover even the required re-delivery bond, which should be double the value of the chattel. Therefore, the MTC's denial of their motion for redelivery was correct.
Main Doctrine
A writ of replevin issued by a Metropolitan Trial Court may be served and enforced anywhere in the Philippines, and the jurisdiction of a court is determined by the amount of the claim alleged in the complaint, not by the value of the chattel seized in ancillary proceedings.