G.R. No. 227147 . July 30, 2018.
RADIOWEALTH FINANCE COMPANY, INC., PETITIONER, VS. ALFONSO O. PINEDA, JR., AND JOSEPHINE C. PINEDA, RESPONDENTS.

FACTS

Petitioner Radiowealth Finance Company, Inc. extended a loan to respondents Alfonso and Josephine Pineda, secured by a chattel mortgage on their 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 Radiowealth Finance Company, Inc. has a branch/office, a[t] its sole option.” Upon respondents’ default, petitioner filed a complaint for sum of money and damages with an application for a writ of replevin before the Regional Trial Court (RTC) of San Mateo, Rizal, alleging it had a branch in that locality.
The RTC initially issued a writ of replevin. However, in an Amended Order, it recalled the writ and dismissed the complaint for lack of jurisdiction. The RTC reasoned that since petitioner’s principal place of business was in Mandaluyong City and respondents resided in Pampanga, it had no jurisdiction over any of the parties. Petitioner’s motion for reconsideration was denied, prompting this direct recourse to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the RTC correctly dismissed petitioner’s complaint on the ground of lack of jurisdiction.

RULING

The Supreme Court granted the petition, reversing the RTC’s orders. The Court held that the RTC committed a grave error by confusing the concepts of jurisdiction and venue. Jurisdiction refers to a court’s authority to hear and decide a case, conferred by law and determined by the allegations in the complaint and the nature of the relief sought. Venue, in contrast, pertains merely to the geographical location or place where the action is to be tried, which is a matter of procedural law.
The complaint was for a sum of money involving P510,132.00. Pursuant to Section 19(8) of Batas Pambansa Blg. 129, as amended, the RTC indisputably had jurisdiction over the subject matter, as the amount claimed exceeded the threshold for its exclusive original jurisdiction. Therefore, the dismissal based on “lack of jurisdiction” was incorrect.
Even if the RTC’s concern was properly characterized as one of improper venue, it still erred in dismissing the case motu proprio. Under the Rules of Court, objections to improper venue must be raised by the defendant in a motion to dismiss or in the answer; otherwise, they are deemed waived. A court cannot dismiss a case on the ground of improper venue on its own initiative. Furthermore, the contractual stipulation in the promissory note expressly allowed filing in a place where petitioner had a branch, which included San Mateo, Rizal. Consequently, the RTC’s orders were set aside, and the case was reinstated and remanded for further proceedings.