G.R. No. L-32217 August 15, 1988
MERCEDES SY, petitioner, vs. JUDGE DOMINADOR C. MINA, Municipal Court, Cabatuan, Isabela, M. CHUAKAY & SONS RICE MILL, INC., Quezon City Sheriff, L.F. VILLASENOR and Deputy Sheriff J. G. ENRIQUEZ, respondents.

FACTS

Private respondent M. Chuakay & Sons Rice Mill, Inc. filed a complaint for sum of money with a prayer for a writ of preliminary attachment against petitioner Mercedes Sy in the Municipal Court of Cabatuan, Isabela. The complaint alleged that Sy purchased rice in Quezon City, issued dishonored checks as payment, and had agreed via a sales invoice to submit to the jurisdiction of the courts of Cabatuan, Isabela, for any action arising from the transaction. The respondent judge issued the writ of attachment. Petitioner moved to dismiss the complaint and discharge the writ, arguing improper venue as she was a resident of Quezon City and the transaction occurred there. She contended the sales invoice, which was unsigned by the buyer, could not constitute a valid written agreement to change venue. The municipal court denied her motion and subsequent motion for reconsideration, prompting this petition for prohibition and certiorari.

ISSUE

Whether the unsigned sales invoice receipt containing a venue stipulation constitutes a valid written agreement that changes the proper venue of the action from Quezon City to Cabatuan, Isabela.

RULING

The Supreme Court dismissed the petition, upholding the venue in Cabatuan, Isabela. The legal logic centers on the principle of implied acceptance of contractual terms. Petitioner argued that under Section 3, Rule 4 of the Revised Rules of Court, an agreement to change venue must be a written document explicitly signed by both parties. The Court rejected this formalistic interpretation. It ruled that the buyer’s acceptance of the goods and use thereof, without objection to the terms stated in the invoice, constitutes an implied conformity to all its conditions, including the venue clause. This ruling is anchored on precedents, specifically Pan Pacific Company (Phil.) vs. Advertising Corporation and Naga Development v. Court of Appeals, which established that a party’s failure to object to invoice terms upon receipt and use of the goods binds them to those terms. Therefore, the unsigned invoice, when coupled with the petitioner’s acceptance of the rice and her issuance of payment checks, effectively served as a written agreement altering venue. The Court found no merit in the petition and remanded the case for trial on the merits.