Radiowealth Finance Company v. Pineda
REITERATIONFacts
The Antecedents: Radiowealth Finance Company, Inc. (petitioner) extended a loan to Alfonso O. Pineda, Jr. and Josephine C. Pineda (respondents) evidenced by a Promissory Note. The Promissory Note stipulated 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 Radiowealth has a branch/office, at its sole option. Due to respondents' default, petitioner filed a complaint for sum of money and damages with application for a Writ of Replevin before the Regional Trial Court (RTC) of San Mateo, Rizal, alleging it has a branch in San Mateo, Rizal. Procedural History: The RTC issued a Writ of Replevin. However, it later issued an Amended Order recalling the writ and dismissing the complaint on the ground of lack of jurisdiction, citing that petitioner's principal place of business is in Mandaluyong City and respondents' residence is in Porac, Pampanga. The RTC denied petitioner's motion for reconsideration. The Petition: Petitioner filed a petition for review on certiorari assailing the RTC's Amended Order and Order dismissing the complaint.
Issue(s)
Whether the RTC correctly dismissed petitioner's complaint on the ground of lack of jurisdiction. Whether the RTC correctly dismissed petitioner's complaint on the ground of improper venue.
Ruling
The petition is granted. The Amended Order dated July 21, 2016 and the Order dated September 1, 2016 of the RTC are reversed and set aside. The case is reinstated and remanded to the RTC for further proceedings.
Ratio Decidendi
On the issue of jurisdiction: Jurisdiction is defined as the authority to hear and determine a cause and is conferred by the Constitution and law. It is determined by the allegations in the complaint, the law in effect when the action is filed, and the relief sought, irrespective of the plaintiff's entitlement. This is distinct from venue, which pertains to the geographical location of the trial. The RTC erred in dismissing the complaint for lack of jurisdiction because the nature of the action (sum of money) and the amount involved fall within the RTC's jurisdiction as provided by Batas Pambansa Blg. 129, as amended by Republic Act No. 7691. The RTC confused jurisdiction with venue. On the issue of venue: Even assuming that the RTC was referring to venue, it still erred in dismissing the complaint motu proprio. Rule 4 of the Rules of Court governs venue. Section 4(b) allows parties to agree in writing on an exclusive venue. The stipulation in the Promissory Note was restrictive, limiting venue to the National Capital Judicial Region or any place where Radiowealth has a branch. Since petitioner alleged it has a branch in San Mateo, Rizal, venue appears to have been properly laid. Furthermore, improper venue is a procedural infirmity that can be waived. The RTC cannot motu proprio dismiss a case on the ground of improper venue; such objection must be raised by the defendant at the earliest opportunity, either in a motion to dismiss or in the answer. Failure to do so constitutes waiver. Therefore, the RTC's dismissal was erroneous.
Main Doctrine
The Regional Trial Court erred in motu proprio dismissing the complaint on the ground of lack of jurisdiction, as jurisdiction is determined by the allegations in the complaint and the law, while venue pertains to the place of trial and can be waived. Even if venue was improperly laid, the court cannot motu proprio dismiss the case without a timely objection from the defendant.