G.R. No. 103501-03 - Tabuena vs. Sandiganbayan

Petitioner: Radiowealth Finance Company, Inc., a domestic financing corporation with principal address at 7th Floor, DMG Center, Domingo M. Guevara Street, Mandaluyong City.
Respondents: Romeo T. Nolasco and Reynaldo T. Nolasco, both residing in Mandaluyong City and obligors under the financing agreement.

On March 31, 2014, the respondents secured a loan amounting to P1,908,360.00 from Radiowealth Finance Company, Inc.
A Promissory Note was executed on the same day evidencing the loan and its repayment terms over 36 months.
To secure obligational performance, a Chattel Mortgage was constituted over a 2001 Fuso Super Great Dropside Truck.

The respondents defaulted on the installment payments, rendering the entire loan amount due and demandable.
Despite repeated demands for payment by the petitioner, the respondents refused both to settle the outstanding amount and to surrender the truck which served as collateral.
On September 30, 2015, the petitioner filed a complaint for Sum of Money and Damages, coupled with an Application for Writ of Replevin, before the Regional Trial Court (RTC) of San Mateo, Rizal (Branch 75), seeking either payment of the remaining balance of P1,600,153.02 or the repossession and sale of the truck in satisfaction of the debt.

Following an ex parte hearing, the RTC issued an Order on March 28, 2016, directing the issuance of the writ of replevin.
On July 21, 2016, an Amended Order was issued by the RTC, dismissing the case motu proprio for lack of jurisdiction, citing Section 2, Rule 4 of the 1997 Rules of Civil Procedure with reference to the residence of the parties.
The petitioner filed a Motion for Reconsideration on August 16, 2016, arguing the RTC's jurisdiction on the basis of the substantial amount involved and a valid venue stipulation in the promissory note.
The RTC reaffirmed its earlier dismissal in an Order dated September 1, 2016.

The petitioner elevated the case on a petition for review on certiorari, challenging the RTC’s orders on pure questions of law regarding jurisdiction and venue.

Whether the RTC erred in conflating the concepts of jurisdiction and venue when it dismissed the case motu proprio.
Whether the RTC had jurisdiction over the complaint, considering the substantial sum involved, which was well within its monetary threshold.
Whether the stipulation in the promissory note, designating the venue as the proper court within the National Capital Judicial Region or any branch where the petitioner maintains an office, rendered the filing of the case in San Mateo, Rizal proper.
Whether dismissal on the basis of improper venue, absent a timely objection by the respondents, amounted to an undue interference with the parties’ agreed stipulations on venue.