Radiowealth Finance v. Nolasco
REITERATIONFacts
The Antecedents: Radiowealth Finance Company, Inc. (petitioner) extended a loan of P1,908,360.00 to Romeo T. Nolasco and Reynaldo T. Nolasco (respondents) on March 31, 2014, payable in 36 months. The loan was secured by a Chattel Mortgage over a Fuso Super Great Dropside Truck. The respondents defaulted on their payments, leading to the entire loan amount becoming due and demandable. Despite repeated demands, the respondents failed to pay the outstanding balance of P1,600,153.02 and refused to surrender the mortgaged vehicle. Procedural History: On September 30, 2015, the petitioner filed a complaint for Sum of Money and Damages with Application for Writ of Replevin before the Regional Trial Court (RTC) of San Mateo, Rizal. The RTC initially issued a Writ of Replevin. However, on July 21, 2016, the RTC motu proprio issued an Amended Order dismissing the case for lack of jurisdiction, citing that neither the petitioner nor the respondents resided within its territorial jurisdiction. The petitioner moved for reconsideration, arguing that the RTC had jurisdiction and that the venue was proper based on a stipulation in the promissory note. On September 1, 2016, the RTC denied the motion for reconsideration. The Petition: The petitioner filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the RTC's Amended Order and subsequent Order. The petitioner contends that the RTC erred in dismissing the case for lack of jurisdiction and improper venue. The core arguments are that the RTC confused jurisdiction with venue, that the amount involved falls within the RTC's jurisdiction, and that the parties had validly agreed in writing to exclusively bring actions in the National Capital Judicial Region or any place where the petitioner has a branch, making the chosen venue in San Mateo, Rizal proper. Furthermore, the petitioner argues that the RTC should not have dismissed the case motu proprio as improper venue is a privilege that can be waived by the parties.
Issue(s)
Whether the RTC erred in dismissing the case motu proprio for lack of jurisdiction. Whether the RTC erred in dismissing the case motu proprio on the ground of improper venue.
Ruling
The petition is granted. The Amended Order dated July 21, 2016, and Order dated September 1, 2016, of the Regional Trial Court of San Mateo, Rizal, Branch 75, are reversed and set aside. Civil Case No. 2806-15 SM is ordered reinstated, and the RTC is directed to proceed with dispatch.
Ratio Decidendi
On the issue of jurisdiction: The RTC has jurisdiction over the case. Jurisdiction is conferred by law and relates to the nature of the action and the amount involved. Section 19(8) of Batas Pambansa Bilang 129, as amended by Republic Act No. 7691, grants Regional Trial Courts exclusive original jurisdiction over civil cases where the demand exceeds P400,000.00 in Metro Manila. The amount of P1,600,153.02 in this case clearly falls within the RTC's jurisdictional competence. Therefore, the RTC's claim of lack of jurisdiction was erroneous. On the issue of venue: The RTC confused jurisdiction with venue. Venue pertains to the place where the case may be filed and, unlike jurisdiction, may be waived or subjected to agreement by the parties. Section 2, Rule 4 of the 1997 Rules of Civil Procedure, regarding venue for personal actions, is permissive, not restrictive. Furthermore, Section 4(b) of the same Rule explicitly allows parties to agree in writing on the exclusive venue of actions before filing. The promissory note in this case contained a stipulation that any action to enforce payment shall exclusively be brought in the proper court within the National Capital Judicial Region or in any place where the petitioner has a branch or office, at its sole option. The petitioner's choice of San Mateo, Rizal, where it has a branch, was therefore proper and should have been respected. Moreover, the RTC cannot motu proprio dismiss a case on the ground of improper venue; this is a matter personal to the parties and is deemed waived if not raised at the earliest opportunity, such as in a motion to dismiss or in the answer. The RTC's dismissal was an unwarranted interference with the parties' mutually agreed term.
Main Doctrine
The Regional Trial Court (RTC) erred in dismissing the case motu proprio on the ground of improper venue, as venue stipulations are valid and may be agreed upon by the parties, and the RTC cannot pre-empt the defendant's prerogative to object to the venue.