Pillars Property Corp. v. Century Communities Corp.
REITERATIONFacts
The Antecedents: Petitioner Pillars Property Corporation (PPC) filed a complaint for sum of money against respondent Century Communities Corporation (CCC) for unpaid progress billings amounting to ₱6.7 million in connection with a construction contract. PPC also impleaded People's General Insurance Corporation (PGIC), the issuer of performance bonds for CCC. Procedural History: CCC filed a Motion to Dismiss based on an exclusive venue stipulation in the contract, which designated Makati courts as the exclusive venue for litigation. PPC opposed, arguing that the inclusion of PGIC, a non-party to the contract, made the general rule on venue applicable. The Regional Trial Court (RTC) granted CCC's motion, dismissing the case for improper venue. PPC's motion for reconsideration was denied. PPC then filed a Petition for Certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC. The CA dismissed PPC's petition, ruling that the proper remedy was appeal, not certiorari. The Petition: PPC filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's dismissal of its certiorari petition.
Issue(s)
Whether the Court of Appeals erred in concluding that the remedy availed of by petitioner PPC was erroneous. Whether the Regional Trial Court committed grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing the complaint for improper venue.
Ruling
The Supreme Court partly granted the petition, reversing and setting aside the Court of Appeals Resolutions and sustaining the Regional Trial Court Orders. The Court held that PPC availed of the correct remedy (certiorari) but found that the RTC did not commit grave abuse of discretion in dismissing the case for improper venue.
Ratio Decidendi
On the propriety of the remedy: The Court held that the Court of Appeals erred in dismissing PPC's Rule 65 certiorari petition. Citing Rule 41, Section 1(g) of the Rules of Court, the Court clarified that an order dismissing an action without prejudice is not subject to appeal and may be reviewed via a Rule 65 certiorari petition. The dismissal of the case by the RTC on the ground of improper venue was considered a dismissal without prejudice, as it does not bar the refiling of the same action. Therefore, PPC correctly availed of the remedy of certiorari. On the alleged grave abuse of discretion by the RTC: Despite finding that PPC availed of the correct remedy, the Court did not find that the RTC acted with grave abuse of discretion. The Court reiterated that Section 4(b) of Rule 4 of the Rules of Court allows parties to agree in writing on the exclusive venue of actions. Given the explicit stipulation in the contract between PPC and CCC designating Makati courts as the exclusive venue, the RTC had a sufficient legal basis to apply Section 4(b) of Rule 4 and dismiss the case filed in Parañaque City. The Court found that the RTC's application of the exclusive venue stipulation, even with the inclusion of PGIC as a party, was not a manifest disregard of basic rules and procedures, but at most, a mere error of judgment, which does not constitute grave abuse of discretion.
Main Doctrine
An order dismissing an action based on improper venue is a dismissal without prejudice and is not appealable; the proper remedy is a special civil action for certiorari under Rule 65.