G.R. No. 186993 ; August 22, 2012
THEODORE and NANCY ANG, represented by ELDRIGE MARVIN B. ACERON, Petitioners, vs. SPOUSES ALAN and EM ANG, Respondents.

FACTS

Petitioners Theodore and Nancy Ang, residents of Los Angeles, USA, lent US$300,000 to respondents spouses Alan and Em Ang, residents of Bacolod City, evidenced by a 1992 promissory note. After repeated demands for payment went unheeded, petitioners, through a Special Power of Attorney (SPA), authorized Atty. Eldrige Marvin B. Aceron, a resident of Quezon City, to file a collection suit. On September 15, 2006, Atty. Aceron filed the complaint with the Regional Trial Court (RTC) of Quezon City.
Respondents moved to dismiss the complaint on grounds of improper venue and prescription. They argued that under Section 2, Rule 4 of the Rules of Court, venue for personal actions lies either where the plaintiffs or the defendants reside. Since petitioners reside abroad and respondents reside in Bacolod City, the proper venue should be the RTC of Bacolod City, not Quezon City where only the attorney-in-fact resides. The RTC denied the motion, ruling that venue was properly laid in Quezon City as Atty. Aceron, as the constituted attorney-in-fact and representative filing the suit, could be considered for venue purposes.

ISSUE

Whether the Court of Appeals committed reversible error in ruling that the complaint must be dismissed on the ground of improper venue.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The ruling is grounded on a strict interpretation of the rules on venue. Section 2, Rule 4 of the Rules of Court states that personal actions shall be filed in the court where the plaintiff or the defendant resides, at the plaintiff’s election. The term “plaintiff” refers to the real party-in-interest, not their representative. The Court emphasized that an attorney-in-fact is merely a procedural representative or agent of the principal. The residence of such an agent is irrelevant for determining proper venue; only the residence of the real parties in interest—the principal or the defendant—controls.
Since the petitioners-plaintiffs are residents of Los Angeles, which is outside Philippine jurisdiction, the rule dictates that the suit must be filed in the place of the defendants’ residence to ensure a fixed and determinate venue. The defendants, the Spouses Ang, reside in Bacolod City. Therefore, the exclusive proper venue was the RTC of Bacolod City. Filing the case in Quezon City based solely on the residence of the attorney-in-fact was improper. The rules on venue are designed to ensure orderly administration of justice and prevent plaintiffs from capriciously choosing forum. Allowing venue to be based on an agent’s residence would contravene this principle and the clear language of the procedural rule. Consequently, the dismissal of the complaint by the CA for improper venue was correct.