Case Digest (G.R. No. 161026)
Facts:
Hyatt Elevators and Escalators Corporation v. Goldstar Elevators, Phils., Inc., G.R. No. 161026, October 24, 2005, the Supreme Court Third Division, Panganiban, J., writing for the Court.Petitioner Hyatt (hereafter Hyatt) is a domestic corporation that originally filed suit; Respondent Goldstar (hereafter Goldstar) is a domestic corporation later impleaded in the action. Hyatt instituted a Complaint on February 23, 1999 for unfair trade practices and damages under Articles 19–21 of the Civil Code against LG Industrial Systems Co. Ltd. (LGISC) and LG International Corporation (LGIC), alleging wrongful termination of an exclusive distributorship and seeking monetary and exemplary damages.
After motions to dismiss by LGISC and LGIC were denied by the Regional Trial Court (RTC), Hyatt filed a motion to amend on December 4, 2000 to substitute LGISC with LG Otis Elevator Company (LG OTIS) as successor-in-interest and to implead Goldstar as an additional defendant. The RTC admitted the Amended Complaint on January 8, 2001; a motion for reconsideration by the LG defendants was denied on October 4, 2001.
On April 12, 2002 Goldstar filed a Motion to Dismiss the Amended Complaint on the grounds of improper venue and failure to state a cause of action. In an Order dated May 27, 2002 the RTC, Branch 213, Mandaluyong City, denied the motion; Goldstar's motion for reconsideration was denied on October 1, 2002. Goldstar then filed a petition for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC in denying the Motion to Dismiss.
The CA in CA‑GR SP No. 74319 (Decision dated June 26, 2003, penned by Justice Remedios A. Salazar‑Fernando) found that the RTC committed grave abuse of discretion and dismissed the case on the ground of improper venue, holding that the corporations’ residence for venue purposes was Makati as stated in their articles of incorporation. The CA denied Goldstar’s motion for reconsideration in a Resolution dated November 27, 2003. Hyatt then filed a petition for review on certiorari under Rule 45 of the Rules of Court be...(Pro-only)
Issues:
- Did the Court of Appeals err in reversing the RTC and holding that venue was improper because the plaintiff-corporation’s residence is determined by the principal office stated in its Articles of Inc...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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