GR L 58287; (August, 1982) (Digest)
G.R. No. L-58287 August 19, 1982
EDUARDO VILLANUEVA, petitioner, vs. JUDGE LORENZO MOSQUEDA, Court of First Instance of Pampanga, San Fernando Branch VII, and HEIRS OF BASILIO BONIFACIO, respondents.
FACTS
The case concerns the proper venue for an ejectment suit. The parties, lessor Basilio Bonifacio (later represented by his heirs) and lessee Eduardo Villanueva, executed a supplementary lease agreement for a house in Tondo, Manila. A specific stipulation provided that if the lessor violated the contract, suit could be filed in Manila, but if the lessee violated it, suit could be filed in Masantol, Pampanga, the lessor’s residence. In June 1980, the heirs filed an ejectment suit against Villanueva in the Municipal Court of Masantol.
Villanueva moved to dismiss, arguing that venue was improperly laid. He contended that under the Rules of Court, an ejectment action must be brought where the property is situated (Manila), and the contractual stipulation fixing venue in Masantol was void. The municipal court denied his motion. Villanueva then filed a certiorari petition in the Court of First Instance of Pampanga, which dismissed it, upholding the venue stipulation as a valid waiver of the legal venue.
ISSUE
Whether the contractual stipulation on venue in the lease agreement is valid and binding, thereby making the ejectment suit filed in the Municipal Court of Masantol proper.
RULING
The Supreme Court dismissed the petition, affirming the lower court’s decision. The Court clarified that the rule requiring ejectment suits to be brought in the municipality or city where the property is located (Section 1[a], Rule 4) pertains to venue, not jurisdiction over the subject matter. Jurisdiction over ejectment cases is vested in inferior courts, including the Municipal Court of Masantol.
Crucially, Section 3 of Rule 4 allows parties, by written agreement, to change or transfer venue from one province to another. The stipulation in the parties’ supplementary lease agreement constitutes such a valid, binding, and enforceable agreement on venue. The Court cited precedents like Hoechst Philippines, Inc. vs. Torres and Bautista vs. De Borja to support the enforceability of venue agreements. This case was distinguished from situations where venue stipulations are merely permissive and not exclusive; here, the agreement clearly and validly designated Masantol as the venue for suits against the lessee. Therefore, the filing of the ejectment case in Masantol was proper.