Facts:

In the case of Theodore and Nancy Ang, represented by Eldrige Marvin B. Aceron, petitioners, against Spouses Alan and Em Ang, respondents, the events unfolded from a loan transaction dated September 2, 1992, whereby the respondents borrowed Three Hundred Thousand U.S. Dollars (US$300,000.00) from the petitioners. The respondents executed a promissory note promising to repay the loan, which attracted a ten percent (10%) annual interest upon demand. Despite several demands for payment, including a formal demand letter sent on August 28, 2006, the respondents remained in default, leading to the outstanding debt increasing to Seven Hundred Nineteen Thousand, Six Hundred Seventy-One U.S. Dollars and Twenty-Three Cents (US$719,671.23). Consequently, on August 6, 2006, the petitioners, residing in Los Angeles, California, USA, executed Special Powers of Attorney to authorize Atty. Aceron to represent them in a legal action against the respondents. The complaint was filed with the Regio

...

Facts:

Loan Agreement and Promissory Note

• On September 2, 1992, spouses Alan and Em Ang (respondents) obtained a US$300,000 loan from Theodore and Nancy Ang (petitioners).
• On the same day, the respondents executed a promissory note promising to pay the loan amount with an annual interest rate of 10%.

Demand for Payment and Accrual of Interest

• Despite repeated demands by the petitioners, the respondents failed to remit payment on the loan.
• By August 28, 2006, the outstanding debt had accrued to US$719,671.23, inclusive of the accumulated interest.

Initiation of Litigation

• On August 6, 2006, while residing in Los Angeles, California, USA, the petitioners executed Special Powers of Attorney in favor of Attorney Eldrige Marvin B. Aceron to act on their behalf.
• Consequently, on September 15, 2006, Atty. Aceron filed a complaint for collection of sum of money before the RTC of Quezon City.

Motion to Dismiss and RTC Proceedings

• On November 21, 2006, the respondents moved to dismiss the complaint on the ground of improper venue and prescription.
• The respondents contended that the proper venue should have been in Bacolod City—where they reside—instead of Quezon City.
• The RTC of Quezon City, on April 12, 2007, issued an Order denying the respondents’ motion to dismiss, relying on the fact that the Special Power of Attorney designated Atty. Aceron’s address in Quezon City as sufficient for venue purposes.
• A subsequent motion for reconsideration by the respondents was likewise denied by the RTC in its Order dated August 27, 2007.

Court of Appeals Proceedings

• The respondents then elevated the issue to the Court of Appeals (CA) via a petition for certiorari, challenging the filing venue based on the residence of the parties.
• On August 28, 2008, the CA annulled and set aside the RTC orders, effectively dismissing the petitioners’ complaint on the ground of improper venue.
• The CA affirmed its decision through a Resolution issued on February 20, 2009.

Issue:

Proper Determination of Venue

• Whether the filing of the complaint in the RTC of Quezon City, based solely on the residence of the attorney-in-fact, is proper under the Rules of Court.
• Whether the residence of the real parties in interest (i.e., petitioners and respondents) should exclusively govern venue determination.

Status of the Attorney-in-Fact

• Whether Atty. Aceron, despite being the designated representative through Special Power of Attorney, is considered a real party in interest in the context of venue determination.
• The implications of considering or not considering the attorney’s residence when deciding the proper venue.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)