Title
Supreme Court
Radiowealth Fice Co., Inc. vs. Pineda, Jr.
Case
G.R. No. 227147
Decision Date
Jul 30, 2018
RTC dismissed loan recovery case for lack of jurisdiction; SC ruled RTC erred, distinguishing jurisdiction from venue, reinstating the complaint.

Case Digest (G.R. No. 227147)
Expanded Legal Reasoning Model

Facts:

  • Loan Transaction
    • On October 23, 2014, Radiowealth Finance Company, Inc. (petitioner) extended a loan of ₱557,808.00 to Alfonso O. Pineda, Jr. and Josephine C. Pineda (respondents), evidenced by a Promissory Note payable in 24 monthly installments of ₱23,242.00.
    • The loan was secured by a Chattel Mortgage over the respondents’ vehicle. The Promissory Note contained an exclusive venue clause providing that any action to enforce payment “shall exclusively be brought in the proper court within the National Capital Judicial Region or in any place where Radiowealth Finance Company, Inc. has a branch/office, at its sole option.”
  • Default and RTC Proceedings
    • The respondents defaulted, and by June 8, 2015, the outstanding balance reached ₱510,132.00, exclusive of penalties. Petitioner’s demand for payment went unheeded.
    • On October 12, 2015, petitioner filed a complaint for sum of money and damages with application for a Writ of Replevin before the RTC of San Mateo, Rizal, Branch 75, alleging it had a branch there.
    • On March 28, 2016, the RTC issued the Writ of Replevin. On July 21, 2016, it issued an Amended Order recalling the writ and dismissing the complaint for lack of jurisdiction, reasoning that petitioner’s principal place of business was in Mandaluyong City and respondents resided in Porac, Pampanga.
    • Petitioner moved for reconsideration, which was denied on September 1, 2016. Petitioner then filed a petition for review on certiorari with the Supreme Court.

Issues:

  • Whether the Regional Trial Court correctly dismissed petitioner’s complaint on the ground of lack of jurisdiction.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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