Universal Robina Corporation v. Lim
REITERATIONFacts
1. The Antecedents: This case originated from a contract of sale where Universal Robina Corporation (petitioner) sold grocery products to Albert Lim (respondent) for P808,059.88. After making partial payments, respondent failed to settle the remaining balance despite repeated demands from the petitioner. 2. Procedural History: Petitioner filed a complaint for a sum of money against respondent before the Regional Trial Court (RTC) of Quezon City. The RTC initially dismissed the complaint motu proprio for lack of jurisdiction and improper venue. However, upon motion for reconsideration and amended complaint alleging a venue stipulation, the RTC admitted the amended complaint. Respondent was declared in default for failure to file an answer. Subsequently, the RTC again dismissed the complaint motu proprio for improper venue, finding no connection between the parties and Quezon City, and that the venue stipulation was not sufficiently established. Petitioner's motion for reconsideration was denied. Petitioner then filed a petition for review with the Court of Appeals (CA), which was dismissed for failure to attach an explanation for service by registered mail instead of personal service. The CA also denied petitioner's motion for reconsideration. 3. The Petition: Petitioner seeks a review on certiorari under Rule 45 of the Rules of Civil Procedure, assailing the CA's resolutions. The core issue presented is whether a trial court may dismiss a complaint motu proprio on the ground of improper venue. Petitioner argues that improper venue is a defense that can be waived and is not among the grounds for motu proprio dismissal explicitly enumerated in the Rules of Civil Procedure, unlike lack of jurisdiction, litis pendentia, res judicata, or prescription. Petitioner contends that the RTC erred in dismissing the case motu proprio and that the respondent, having been declared in default, lost his right to question the venue.
Issue(s)
Whether the trial court may dismiss a complaint motu proprio on the ground of improper venue. Whether the respondent waived his right to question the venue by failing to file an answer and being declared in default.
Ruling
The petition is GRANTED. The assailed Resolutions of the Court of Appeals are REVERSED. The Regional Trial Court, Branch 227, Quezon City is ordered to REINSTATE Civil Case No. Q-99-37791 and conduct an ex parte hearing for the reception of petitioner’s evidence and dispose of the case with dispatch.
Ratio Decidendi
On the issue of motu proprio dismissal for improper venue: The Supreme Court reiterated that a trial court may not dismiss a complaint motu proprio on the ground of improper venue. Section 1, Rule 9 of the Rules of Civil Procedure explicitly enumerates the grounds upon which a court may dismiss a claim motu proprio: lack of jurisdiction over the subject matter, another action pending between the same parties for the same cause (litis pendentia), action barred by prior judgment (res judicata), or action barred by statute of limitations. Improper venue is not among these grounds. The Court emphasized that improper venue, if not raised in a motion to dismiss or in the answer, is deemed waived. Dismissing a case motu proprio for improper venue constitutes a procedural shortcut that violates the rules and deprives parties of their right to be heard. The Court cited Dacoycoy v. Intermediate Appellate Court and Rudolf Lietz Holdings Inc. v. Registry of Deeds of Parañaque in support of this principle, highlighting that justice and fairness require adherence to procedural rules. On the issue of waiver of venue by default: The Court held that since the respondent failed to file an answer and was declared in default, he lost his standing in court and consequently, his right to adduce evidence and present his defense. This includes the right to question the propriety of the venue of the action. By failing to raise the objection of improper venue in a timely manner, either through a motion to dismiss or in his answer, the respondent is deemed to have waived such objection. The trial court's initial dismissal motu proprio was erroneous, and its subsequent dismissal after the respondent was declared in default was also improper, as the respondent had already waived his right to question venue.
Main Doctrine
A trial court may not dismiss a complaint motu proprio on the ground of improper venue, as this is not one of the grounds for motu proprio dismissal enumerated in Section 1, Rule 9 of the Rules of Court. Improper venue, if not raised in a motion to dismiss or in the answer, is deemed waived.