Title
Bautista vs. De Borja
Case
G.R. No. L-20600
Decision Date
Oct 28, 1966
A dispute over unpaid machinery purchases led to improper venue claims; Supreme Court ruled venue stipulation in contracts was valid, dismissing the case.
Font Size:

Case Digest (G.R. No. L-20600)

Facts:

Background of the Case

  • On December 28, 1961, G. A. Machineries, Inc. (plaintiff) filed a complaint against Marino A. Bautista (defendant) in the Court of First Instance of Bulacan, docketed as Civil Case No. 2486.
  • The complaint alleged that on January 27, 1960, Bautista purchased personal properties valued at P83,800.00 from G. A. Machineries, Inc., paying a down payment of P12,570.00 and agreeing to pay the balance of P71,230.00 in 11 monthly installments.
  • A chattel mortgage contract was executed to secure the unpaid balance, with the stipulation that failure to pay would allow the plaintiff to take possession of the properties, foreclose the mortgage, and claim 25% of the total amount due as liquidated damages and attorney’s fees.
  • Bautista failed to pay his obligations, and the plaintiff sought to foreclose the mortgage but was unable to proceed due to Bautista’s refusal to surrender the properties.

Plaintiff’s Prayer

  • The plaintiff prayed for:
    1. Delivery of the personal properties or issuance of a writ of replevin.
    2. Payment of P20,217.52 as liquidated damages and attorney’s fees.
    3. Payment of P71,230.00 plus 12% interest per annum from February 28, 1960, in case of non-delivery of the properties.

Defendant’s Motions to Dismiss

  • On April 2, 1962, Bautista filed a motion to dismiss on two grounds:
    1. Another action was pending between the same parties for the same cause in the Court of First Instance of Manila (Civil Case No. 27110).
    2. The filing of the complaint in Bulacan constituted multiplicity of suits, which is prohibited by the Rules of Court.
  • On April 30, 1962, Bautista filed a supplemental motion to dismiss, arguing that venue was improperly laid because the sales and chattel mortgage contracts stipulated that any litigation arising from the contracts should be filed in the City of Manila.

Trial Court’s Orders

  • On May 8, 1962, the trial court suspended proceedings pending the resolution of Civil Case No. 27110 in Manila.
  • On October 12, 1962, the trial court reconsidered its earlier order, denied Bautista’s supplemental motion to dismiss, and set the case for hearing in November 1962.
  • Bautista moved for reconsideration and sought to cancel the hearing, but the trial court denied his motion and allowed the plaintiff to present evidence ex parte due to Bautista’s absence.

Petition to the Supreme Court

  • Bautista filed a petition for certiorari and prohibition in the Supreme Court, seeking to annul the trial court’s orders and prohibit further proceedings in Civil Case No. 2486.
  • He argued that the trial court acted with grave abuse of discretion in denying his motions to dismiss and allowing the case to proceed despite the improper venue.

Issue:

  1. Whether the trial court acted with grave abuse of discretion in denying Bautista’s motions to dismiss based on improper venue.
  2. Whether the stipulation in the contracts fixing the venue in the City of Manila was valid and enforceable.
  3. Whether the trial court should have refrained from proceeding with the case after Bautista manifested his intention to file a petition for certiorari and prohibition.

Ruling:

The Supreme Court granted the writ of prohibition and ordered the dismissal of the complaint in Civil Case No. 2486, without prejudice to the plaintiff filing the complaint in the proper court in the City of Manila.

Ratio:

  1. Validity of Venue Stipulation: The parties expressly agreed in their contracts that any litigation arising from or connected to the contracts would be filed in the City of Manila. This stipulation was clear, valid, and enforceable, as it did not contravene public policy or prejudice third parties. The Rules of Court allow parties to change or transfer venue by written agreement.
  2. Improper Venue: The action was improperly filed in Bulacan, as the contracts stipulated that the venue should be in the City of Manila. The improper venue was clear on the record, and Bautista timely raised this issue in his motion to dismiss.
  3. Grave Abuse of Discretion: The trial court acted with grave abuse of discretion in denying Bautista’s motions to dismiss based on improper venue. A writ of prohibition is a proper remedy when a trial court erroneously denies a motion to dismiss on the ground of improper venue.
  4. Unnecessary to Address Other Issues: With the resolution of the venue issue, the Supreme Court found it unnecessary to address the other issues raised by Bautista.

Conclusion:

The Supreme Court ruled in favor of Bautista, holding that the trial court committed grave abuse of discretion in denying his motions to dismiss based on improper venue. The complaint was dismissed without prejudice to the plaintiff refiling it in the proper court in the City of Manila.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.