G.R. No. 125078/G.R. No. 125598/G.R. No. 126654/G.R. No. 127856/G.R. No. 128398; May 30, 2011
BERNABE L. NAVIDA, ET AL., Petitioners, vs. HON. TEODORO A. DIZON, JR., Presiding Judge, Regional Trial Court, Branch 37, General Santos City, SHELL OIL CO., DOW CHEMICAL CO., OCCIDENTAL CHEMICAL CORP., STANDARD FRUIT CO., STANDARD FRUIT & STEAMSHIP CO., DOLE FOOD CO., INC., DOLE FRESH FRUIT CO., DEL MONTE FRESH PRODUCE N.A., DEL MONTE TROPICAL FRUIT CO., CHIQUITA BRANDS INTERNATIONAL, INC. and CHIQUITA BRANDS, INC., Respondents.

[Consolidated with G.R. No. 125598: THE DOW CHEMICAL COMPANY and OCCIDENTAL CHEMICAL CORPORATION, Petitioners, vs. BERNABE L. NAVIDA, ET AL., Respondents.]

FACTS

This is a consolidation of several petitions arising from a complaint for damages filed by numerous Filipino agricultural workers (Navida, et al.) against several foreign corporations (Shell, Dow, Occidental, Standard Fruit, Dole, Del Monte, and Chiquita). The workers alleged they suffered injuries from exposure to a pesticide called dibromochloropropane (DBCP) while working on banana plantations in the Philippines. The foreign corporations moved to dismiss the complaint on grounds of improper venue and lack of jurisdiction. The Regional Trial Court (RTC) of General Santos City, Branch 37, presided by Judge Teodoro A. Dizon, Jr., granted the motion to dismiss. The RTC held that the action was a personal action and, under the Rules of Court, should have been filed either where the plaintiffs resided or where the defendants resided. Since none of the defendant foreign corporations resided in General Santos City, venue was improperly laid. The workers and some of the corporate defendants filed various petitions challenging the RTC’s order.

ISSUE

The principal issue is whether the RTC correctly dismissed the complaint on the ground of improper venue.

RULING

The Supreme Court DENIED the petitions and AFFIRMED the RTC’s order dismissing the complaint for improper venue.
The Court ruled that the action filed by the workers is a personal action for damages based on alleged tortious acts. Under Section 2, Rule 4 of the Rules of Court, a personal action may be commenced and tried in the court where the plaintiff or any of the principal plaintiffs resides, or where the defendant or any of the principal defendants resides, at the election of the plaintiff. The Court found that none of the principal defendants (the foreign corporations) resided in General Santos City. The workers’ argument that venue was proper because some defendants operated or did business in the city was unavailing. The concept of “resides” for venue purposes refers to a party’s permanent home or legal residence, which for a domestic corporation is its principal place of business as stated in its articles of incorporation, and for a foreign corporation not licensed to do business in the Philippines, is wherever it may be found. The corporate defendants were foreign corporations not licensed to do business in the Philippines; therefore, they could not be considered residents of General Santos City. Consequently, the workers’ choice of venue was improper. The RTC did not commit grave abuse of discretion in dismissing the complaint. The Court also addressed and rejected ancillary arguments, including the applicability of the “convenience of the plaintiffs” principle and forum non conveniens, upholding the primacy of the venue rules.