G.R. No. 156596 - Infante vs. Aran Builders, Inc.

An original judgment was rendered by the Regional Trial Court of Makati City (Makati RTC) in an action for specific performance and damages (Civil Case No. 15563).
The judgment, which became final and executory on November 16, 1994, ordered petitioner, Adelaida Infante, to perform several acts including:

Delivering complete plans and documents;
Executing the deed of sale for Lot No. 11, Block 9, Phase 3-A1, Ayala Alabang Subdivision for a price of P500,000.00;
Paying taxes related to the sale and obtaining the necessary registration with the Registry of Deeds; and
Receiving a sum of P321,918.25 upon compliance, among other orders.

This judgment also provided for the payment of attorney’s fees and dismissed other claims such as moral and exemplary damages and counterclaims.

Aran Builders, Inc. (private respondent) filed an action for revival of judgment on June 6, 2001 before the Regional Trial Court of Muntinlupa City (Muntinlupa RTC, Branch 276) to enforce the previously rendered Makati RTC judgment.
Petitioner (Adelaida Infante) opposed the revival, filing a motion to dismiss on the grounds of lack of jurisdiction over the parties and improper venue.
The Muntinlupa RTC denied the motion to dismiss, noting that although the original judgment was rendered by Makati RTC, the subject matter (real property located in Muntinlupa City) warranted filing the revival action in Muntinlupa given the creation of its own Regional Trial Court.
Petitioner’s subsequent motion for reconsideration was denied on September 28, 2001.

Petitioner elevated the case through a special civil action for certiorari with the Court of Appeals (CA) alleging grave abuse of discretion amounting to a lack or excess of jurisdiction concerning the venue determination.
Petitioner argued that:

The action for revival of judgment is personal in nature, echoing past rulings in Aldeguer v. Gemelo and Donnelly v. Court of First Instance of Manila; and
The complaint should be filed in either Makati City or Parañaque City (depending on the residence of the parties), not in Muntinlupa City where the real property is located.

Private respondent maintained that the revival action was “quasi in rem” (or real) as it affected an adjudicated right over a parcel of land in Muntinlupa City, thus situating the proper venue in Muntinlupa.

The case involved the interpretation of Section 6, Rule 39 of the 1997 Rules of Civil Procedure regarding the enforcement of final and executory judgments and the subsequent determination of venue.
The CA relied on:

Sections 1 and 2 of Rule 4 of the Rules of Court, which distinguish between real actions (affecting title, possession, or interest in real property) and personal actions (relating to the residences of the parties).
Precedents such as Aldeguer v. Gemelo and Donnelly v. Court of First Instance of Manila, while noting that those decisions pertained to judgments for monetary damages and did not involve issues of real property.

Additionally, Section 18 of Batas Pambansa Bilang 129 and Republic Act No. 7154 were cited to explain the territorial jurisdiction of the Regional Trial Courts, particularly the creation of a branch in Muntinlupa City.

On August 12, 2002, the Court of Appeals affirmed the decision of the Muntinlupa RTC, holding that since the revived judgment affected a real property interest, the revival action was inherently a real action.
Petitioner’s motion for reconsideration of the CA decision was denied on January 7, 2003, leading to the present petition before the Supreme Court.

Whether the action for revival of judgment should be categorized as a real action or as a personal action.

Determining the nature of the action depends on whether it affects title, possession, or interest in real property (real action) or merely involves personal obligations.

Whether the proper venue for the revival action is in Muntinlupa City, where the disputed property is located, or in a court based on the residence of the parties (Makati City or Parañaque City).
Whether the denial of the petitioner's motion to dismiss and subsequent rulings by the lower courts constituted grave abuse of discretion, particularly in light of the applicable rules regarding venue and jurisdiction.