G.R. No. 131283 - Ferdez vs. International Corporate Bank

On or about October 26, 1993, Spouses Oscar C. Fernandez and Nenita P. Fernandez purchased a Nissan Sentra Sedan through a financing scheme with International Corporate Bank (now Union Bank of the Philippines).
A chattel mortgage was executed in favor of the bank on November 10, 1993.
The cash purchase price was ₱492,000.00, minus a downpayment of ₱147,500.00, leaving ₱344,500.00 to be financed.
Total payment for 48 monthly installments would amount to ₱553,944.00.

The respondent bank filed an unfounded complaint for a sum of money with replevin (Case No. 983-96) before the Metropolitan Trial Court (MTC) Branch 44, Pasay City.
The petitioners filed an Answer including a Motion to Dismiss for lack of jurisdiction, arguing that the principal amount was ₱553,944.00, which was beyond the jurisdiction of the MTC, but the motion was denied on February 10, 1997.
Petitioners contested the venue, asserting that the bank’s principal office was in Makati while they resided in Quezon City.
Motion for Reconsideration on the dismissal of the jurisdictional motion was denied on May 9, 1997.

At the time the complaint was filed (November 28, 1997), monthly installments were almost fully paid and due to be fully paid on November 26, 1997.
Vehicle mileage upon illegal seizure was only 28,464 kilometers, and petitioners claimed non-default.
Petitioners made attempts to pay installments for August to October 1996 and beyond, but received no statement of delinquency as required by R.A. No. 3165 (Truth in Lending Act).
Petitioners issued a Manager’s Check dated January 7, 1997 for ₱69,168.00 as payment for August to February 1997 but court refused acceptance.
Petitioners’ motion for outright dismissal and lifting of the Writ of Replevin was denied despite asserting that the amount was beyond MTC jurisdiction.

The MTC ruled that the MTC had jurisdiction because the amount sought to be recovered was ₱190,635.00, within its jurisdictional limit.
The Sheriff’s Return confirmed the vehicle was seized on January 7, 1997 and turned over to the plaintiff.
Petitioners failed to post a re-delivery bond within 5 days of the seizure to secure return of the vehicle.

Affirmed the jurisdiction of the MTC based on the amount claimed in the complaint (₱190,635.90), not the value of the vehicle.
Held that the objection to venue was waived since raised for the first time in the Answer, not by motion to dismiss.
Ruled that a Writ of Replevin issued by any branch of the MTC of Metro Manila may be validly served and executed anywhere within Metro Manila.
Denied the petitioners’ suit for certiorari and prohibition to lift the writ and for redelivery of the vehicle.

Contended that the MTC’s jurisdiction was territorially limited within Pasay City and the financing amount exceeded its jurisdictional limit.
Argued the Court of Appeals erred in not granting redelivery of the vehicle within the five-day period required by law after seizure.
Raised procedural objections regarding the bank’s memorandum.

Whether the Writ of Replevin issued by the Metropolitan Trial Court of Pasay City may be served and enforced outside Pasay City.
Whether the Metropolitan Trial Court of Pasay City had jurisdiction over the complaint given the amount involved.
Whether petitioners were entitled to the redelivery of the vehicle seized pursuant to the Writ of Replevin.
Procedural issue regarding the alleged defectiveness of respondent bank’s memorandum.