GR 227146; (November, 2016) (Digest)
G.R. No. 227146. November 14, 2016
RADIOWEALTH FINANCE COMPANY, INC., PETITIONER, VS. ROMEO T. NOLASCO AND REYNALDO T. NOLASCO, RESPONDENTS.
FACTS
Radiowealth Finance Company, Inc. (petitioner) filed a complaint for Sum of Money and Damages with Application for Writ of Replevin against Romeo and Reynaldo Nolasco (respondents) before the Regional Trial Court (RTC) of San Mateo, Rizal. The respondents had defaulted on a loan secured by a chattel mortgage over a motor vehicle. The promissory note contained a stipulation that any action to enforce payment could 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 the petitioner’s sole option.
The RTC initially granted the application for a writ of replevin. However, it later issued an Amended Order dismissing the case motu proprio for lack of jurisdiction. The RTC ruled that since neither the petitioner (whose principal office is in Mandaluyong City) nor the respondents (who reside in Mandaluyong City) resided within the territorial jurisdiction of San Mateo, Rizal, the court could not take cognizance of the case, citing Section 2, Rule 4 of the Rules of Court on venue. The RTC denied the petitioner’s motion for reconsideration.
ISSUE
Whether the Regional Trial Court of San Mateo, Rizal, correctly dismissed the case motu proprio on the ground of improper venue.
RULING
No. The Supreme Court granted the petition, reversing the RTC’s orders. The RTC committed a reversible error by confusing the concepts of jurisdiction and venue. Jurisdiction, which is the court’s authority to hear and decide a case, is conferred by law. Based on Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, the RTC has exclusive original jurisdiction over civil actions where the demand exceeds P400,000.00 in Metro Manila. The amount involved here, P1,600,153.02, is unquestionably within the RTC’s jurisdiction.
Venue, on the other hand, pertains to the geographical location or place where the suit may be filed. Unlike jurisdiction, venue may be waived by the parties and is subject to their agreement. The promissory note contained a valid venue stipulation allowing the petitioner to file the case in the proper court within the National Capital Judicial Region, which includes San Mateo, Rizal. More importantly, objections to improper venue must be raised by the defendant in a motion to dismiss; a court cannot dismiss a case motu proprio on this ground. By doing so, the RTC improperly interfered with the parties’ agreement and pre-empted the respondents’ prerogative to object. The case was ordered reinstated for further proceedings.