Auction in Malinta v. Lubayen
REITERATIONFacts
The Antecedents: Respondent Warren Embes Lubayen filed a complaint for damages against petitioner Auction in Malinta, Inc. before the Regional Trial Court (RTC) of Bulanao, Tabuk, Kalinga. Respondent alleged that he was the highest bidder for a wheel loader in an auction conducted by petitioner, but petitioner failed to produce the item after payment and also failed to deliver a replacement. Procedural History: Petitioner filed a motion to dismiss based on improper venue, citing a stipulation in the Bidders Application and Registration Bidding Agreement that stated, "All Court litigation procedures shall be conducted in the appropriate Courts of Valenzuela City, Metro Manila." The Kalinga RTC granted the motion and dismissed the complaint. Respondent appealed to the Court of Appeals (CA), which reversed the RTC's resolution, holding that venue was properly laid and remanding the case for reinstatement of the complaint. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for review, assailing the CA's decision and arguing that the stipulation on venue exclusively limited litigation to the courts of Valenzuela City.
Issue(s)
Whether the stipulation in the Bidders Application and Registration Bidding Agreement effectively limited the venue of the instant case exclusively to the proper court of Valenzuela City. Whether venue was properly laid before the Regional Trial Court of Bulanao, Tabuk, Kalinga.
Ruling
The petition is denied. The Court of Appeals correctly declared that venue in the instant case was properly laid with the RTC of Bulanao, Tabuk, Kalinga. The decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of exclusive venue stipulation: The Court ruled in the negative. The general rule on venue for personal actions is found in Section 2, Rule 4 of the Rules of Court, which allows the plaintiff to choose where to file the case. While parties may validly agree in writing on an exclusive venue, such a stipulation must contain qualifying or restrictive words to be considered exclusive. In the absence of words like 'exclusively,' 'shall only,' 'to the exclusion of the other courts,' or similar import, a stipulation on venue is deemed merely permissive, an additional forum, not a limitation. The stipulation in this case, "all Court litigation procedures shall be conducted in the appropriate Courts of Valenzuela City, Metro Manila," lacks such restrictive language. Therefore, the Valenzuela courts are merely an additional choice of venue, and the case could also be filed in the RTC of the plaintiff's residence or the defendant's residence. On whether venue was properly laid: Based on the ruling that the stipulation was merely permissive, the Court affirmed the Court of Appeals' finding that venue was properly laid before the RTC of Bulanao, Tabuk, Kalinga. This is because the respondent, as the plaintiff, resides in Tabuk, Kalinga, making the RTC of Bulanao, Tabuk, Kalinga a proper venue under Section 2, Rule 4 of the Rules of Court. The Court reiterated that the filing of the complaint in the RTC of Bulanao, Tabuk, Kalinga was proper, as respondent is a resident of Tabuk, Kalinga.
Main Doctrine
A stipulation on venue is considered merely permissive and not exclusive, unless it contains qualifying or restrictive words such as 'exclusively,' 'shall only,' 'to the exclusion of the other courts,' or words of similar import, clearly indicating the parties' intent to limit the venue to the specified place.