Infante v. Aran Builders
MODIFICATIONFacts
The Antecedents: Aran Builders, Inc. (private respondent) filed an action for revival of judgment against Adelaida Infante (petitioner) before the Regional Trial Court (RTC) of Muntinlupa City. The judgment sought to be revived was rendered by the RTC of Makati City in Civil Case No. 15563, an action for specific performance and damages. The Makati RTC judgment, which became final on November 16, 1994, ordered petitioner to deliver complete plans, an irrevocable power of attorney, tax clearances, tax receipts, and proof of up-to-date payment of subdivision association dues; to execute a deed of sale for Lot No. 11, Block 9, Phase 3-A1, Ayala Alabang Subdivision for P500,000.00 in favor of private respondent; to pay capital gains tax, documentary stamp taxes, and other related taxes; to secure the conformity of Ayala Corporation to the sale; and to register the deed of sale and deliver the certificate of title to Ayala Corporation. Upon petitioner's compliance, private respondent was to pay petitioner P321,918.25. The Makati RTC also ordered petitioner to pay P10,000.00 as attorney's fees. Procedural History: Petitioner filed a motion to dismiss the action for revival of judgment, asserting lack of jurisdiction over the parties and improper venue. The Muntinlupa RTC denied the motion, reasoning that since the property is located in Muntinlupa City and the RTC of Muntinlupa City now has territorial jurisdiction, the action should be filed there. Petitioner's motion for reconsideration was denied. She then filed a special civil action for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the respondent judge. The CA upheld the RTC's order, ruling that the action for revival of judgment, involving title to or possession of real property, is an action in rem and thus should be filed where the property is located. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a Petition for Review on Certiorari with the Supreme Court, claiming the CA erred in finding that the complaint for revival of judgment is an action in rem and was correctly filed with the RTC of Muntinlupa City.
Issue(s)
Whether the action for revival of judgment is a real action or a personal action. Whether the venue of the action for revival of judgment was properly laid with the RTC of Muntinlupa City.
Ruling
The petition is unmeritorious. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the classification of the action for revival of judgment: The Court reiterated that the proper venue depends on whether the action for revival of judgment is a real action or a personal action. Under the Rules of Court, real actions, which affect title to or possession of real property, or interest therein, must be commenced and tried in the proper court having jurisdiction over the area where the real property is situated. Personal actions, on the other hand, may be commenced and tried where the plaintiff or defendant resides. The Court clarified that its rulings in Aldeguer v. Gemelo and Donnelly v. Court of First Instance of Manila, which classified actions for revival of judgment as personal, are not applicable here because the judgments sought to be revived in those cases involved only monetary claims and did not affect title to or interest in real property. In the present case, the complaint for revival of judgment alleges that petitioner was ordered to execute a deed of sale over a parcel of land, pay taxes related to the sale, and register the deed, all of which directly involve private respondent's interest in real property. Therefore, the action for revival of judgment is a real action. On the venue of the action for revival of judgment: Since the action for revival of judgment was determined to be a real action, it must be filed in the court of the place where the realty is located. The Court noted that Section 18 of Batas Pambansa Bilang 129 grants the Supreme Court the authority to define the territory over which a branch of the RTC shall exercise its authority. Originally, Muntinlupa City was under the territorial jurisdiction of the Makati Courts. However, with the creation of the RTC in Muntinlupa City by virtue of Republic Act No. 7154, the RTC of Muntinlupa City now has territorial jurisdiction over properties located within Muntinlupa City. Therefore, the filing of the action for revival of judgment with the RTC of Muntinlupa City, where the property is situated, was proper and did not constitute grave abuse of discretion.
Main Doctrine
An action for revival of judgment is classified as a real action if the original judgment sought to be revived involves title to, possession of, or interest in real property, in which case venue lies in the court where the property is located. Otherwise, it is a personal action, and venue lies where the plaintiff or defendant resides.