Facts:

• On March 15, 1995, Davao Abaca Plantation Company, Inc. (DAPCO) filed a complaint against DOLE Philippines, Inc. (DOLE) in the Regional Trial Court of Manila.
• DAPCO, a corporation under Philippine law, owned a land parcel in Carmen, Davao, covered by Original Certificate of Title No. P-1920, measuring approximately 1,023.81 hectares.
• DOLE had been leasing this property since 1969 for banana cultivation.
• Two lease agreements were executed in 1985, covering 1,004 hectares, with a lease term from February 7, 1984, to February 7, 1994, and a renewal option for six additional years.
• The agreements included a grace period until February 7, 1996, for DOLE to wind up operations if no new terms were agreed upon.
• After the enactment of the Comprehensive Agrarian Reform Law (CARL) in 1988, the Department of Agrarian Reform (DAR) initially deferred the land's coverage but later reversed its position.
• On December 9, 1992, DOLE exercised its option to renew the lease until December 31, 2000.
• DAPCO requested DOLE to intervene in DAR proceedings, but DOLE declined, citing CARL.
• In January 1995, DOLE inquired about DAPCO's intentions regarding the lease, and DAPCO demanded rental payments for 1995.
• DOLE claimed that government actions made it impossible to fulfill its obligations, leading to a cessation of rental payments.
• DAPCO sought a temporary restraining order against DOLE to prevent dealings with third parties and compel compliance with the lease agreements.
• The Court of Appeals dismissed the case on March 13, 1998, for improper venue, asserting it should have been filed in South Cotabato.
• DAPCO's motion for reconsideration was denied, prompting an appeal to the Supreme Court.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled that the complaint was a personal action, and the trial court had jurisdiction over the case.
• The Court held that the venue was properly established in Manila, where DAPCO's principal office was located.
• The Court determined that the issue of ...(Unlock)

Ratio:

• The Supreme Court emphasized that DAPCO's complaint aimed to enforce the lease contract against DOLE, classifying it as a personal action.
• Jurisdiction is determined by the allegations in the complaint, regardless of the merits of the claims.
• DAPCO was not asserting owne...continue reading