Case Digest (G.R. No. 238892)
Facts:
On March 13, 2012, Ley Construction and Development Corporation, represented by its President Janet C. Ley (petitioner), lodged a Complaint for Collection of Sum of Money and Damages against Marvin Medel Sedano, doing business as “Lola Taba Lolo Pato Palengke at Paluto sa Seaside” (respondent), before the Regional Trial Court of Valenzuela City, Branch 75, docketed as Civil Case No. 40-V-12. Petitioner had earlier leased a 50,000-sq.m. parcel in Pasay City from the Philippine National Construction Corporation (PNCC) on January 14, 2005, and on September 11, 2006, subleased 14,659.80 sq.m. to respondent for ten years at a monthly rent of ₱1,174,780.00, with a 10% annual escalation starting the third year. When respondent allegedly failed to pay rent from August through December 2011, totaling ₱8,828,025.46, petitioner made repeated demands, but respondent refused to settle. In answer, respondent asserted that after petitioner’s eviction by court order, PNCC demanded direct paymen...Case Digest (G.R. No. 238892)
Facts:
- Lease and Sublease Agreements
- On January 14, 2005, Ley Construction and Development Corporation (petitioner) leased a 50,000-sq.m. parcel of land in Pasay City from Philippine National Construction Corporation (PNCC).
- On September 11, 2006, petitioner subleased 14,659.80 sq.m. of the parcel to Marvin Medel Sedano (respondent) for ten years starting November 15, 2005, at a monthly rent of ₱1,174,780.00, with annual increases of 10% beginning the third year.
- Alleged Breach and Initial Complaint
- Respondent allegedly failed to pay rent from August to December 2011, amounting to ₱8,828,025.46. Despite demands, he did not settle the arrears.
- On March 13, 2012, petitioner filed a Complaint for Collection of Sum of Money and Damages with the Regional Trial Court (RTC) of Valenzuela City (Civil Case No. 40-V-12).
- Respondent’s Answer, Third-Party Complaint, and Counterclaim
- Respondent contended he paid rents for August–December 2011 directly to PNCC following petitioner’s eviction order, and thus impleaded PNCC in a third-party complaint seeking reimbursement if held liable.
- He invoked an affirmative defense of improper venue, citing Section 21 of the lease contract: “All actions or cases filed in connection with this lease shall be filed with the Regional Trial Court of Pasay City, exclusive of all others.”
- Respondent asserted counterclaims for reimbursement of a ₱3,518,352.00 deposit, ₱400,000.00 overpayment, moral and exemplary damages, and litigation expenses.
- Venue Dispute and RTC Rulings
- Petitioner opposed, arguing the stipulation deprived lower courts of jurisdiction and was void, and that respondent waived any venue objection by participating in motions and counterclaims.
- On June 15, 2015, RTC Valenzuela granted respondent’s motion and dismissed the complaint for improper venue. A reconsideration motion was denied on January 27, 2016.
Issues:
- Whether the RTC of Valenzuela City erred in dismissing the complaint on the ground of improper venue under Section 21 of the lease contract.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)