Case Summary (G.R. No. 154096)
Background Facts
- 1968 & 1972: Ambassador Roberto S. Benedicto and associates organized FEMII and UEC. They allegedly held 65% of shares in trust for Irene Marcos-Araneta.
- March 2000: Irene filed two actions in the Regional Trial Court (RTC) of Batac, Ilocos Norte—Civil Cases Nos. 3341-17 (UEC shares) and 3342-17 (FEMII shares)—seeking reconveyance, accounting, receivership, and a TRO.
- Defendants moved to dismiss, arguing intra-corporate dispute (SEC jurisdiction), improper venue (Irene not a Batac resident), and failure to allege trust acceptance.
- June 29, 2000: RTC dismissed both complaints for improper venue and non-residency of Irene, declaring other issues moot.
- July 2000: Irene moved for reconsideration and simultaneously filed an amended complaint adding her Ilocos Norte trustees.
- October 9, 2000; December 18, 2000; March 15, 2001: RTC admitted the amended complaint, denied motions to dismiss and for reconsideration, and ordered defendants to answer.
Procedural History
- April 10, 2001: Respondents filed their answer but sought certiorari relief from the CA to annul the RTC orders admitting the amended complaint and denying their motions.
- CA issued a TRO and preliminary injunction, then on October 17, 2001 set aside the RTC orders and dismissed the amended complaints for lack of jurisdiction (improper venue).
- CA denied reconsideration on June 20, 2002.
- Petitioners elevated the case to the Supreme Court via Rule 45 review.
Issues Presented
- Did the CA properly allow correction of defective verification and certification of non-forum shopping?
- Did the CA exceed its Rule 65 certiorari jurisdiction by resolving factual issues on the existence and enforceability of the trust?
- Was the RTC’s admission of the amended complaint proper under Section 2, Rule 10?
- Did respondents waive their objection to improper venue?
- Was venue in Batac improper given the nature of the action and Irene’s residency?
Supreme Court’s Legal Analysis
Verification and Non-Forum Shopping
- Verification is a formal, non-jurisdictional requirement. The CA rightly allowed submission of an affidavit authorizing representation.
- The signature of one principal petitioner (Francisca) constituted substantial compliance with non-forum shopping rules.
Certiorari Jurisdiction under Rule 65
- Rule 65 is limited to correcting jurisdictional errors (e.g., grave abuse of discretion).
- The CA improperly resolved factual questions on the trust’s existence and enforceability—matters for trial.
Admission of the Amended Complaint
- Under Section 2, Rule 10, a party may amend once as a matter of right before a responsive pleading.
- Motions to dismiss are not responsive pleadings. The RTC correctly admitted the amended complaint filed prior to any answer.
Waiver of Venue Objection
- Objection to venue must be raised before filing an answer. Respondents consistently asserted improper venue in their motions to dismiss and answers, preserving the defense.
Venue of a Personal Action
- The action is in personam for reconveyance of shareholdings.
- Section 2, Rule 4 fixes venue where the principal plaintiff resides.
- Irene was
Case Syllabus (G.R. No. 154096)
Procedural History
- Petition for review on certiorari under Rule 45 assails CA Decision (Oct. 17, 2001) and Resolution (June 20, 2002) in CA-G.R. SP No. 64246
- CA annulled RTC Branch 17, Batac, Ilocos Norte Orders (Oct. 9, 2000; Dec. 18, 2000; Mar. 15, 2001) admitting petitioners’ amended complaints in Civil Case Nos. 3341-17 & 3342-17
- RTC initially dismissed original complaints (June 29, 2000) for improper venue; denied reconsideration (Aug. 25, 2000)
- Petitioners filed amended complaint (July 17, 2000) adding three co-plaintiffs as trustees and sought admission; RTC granted (Oct. 9, 2000) and later denied motions to dismiss amended complaint
- Respondents elevated venue and other defenses via certiorari to CA, which enjoined RTC proceedings and ultimately dismissed the amended complaints
Statement of Facts
- In 1968 and 1972, Ambassador Roberto S. Benedicto and associates organized Far East Managers and Investors, Inc. (FEMII) and Universal Equity Corporation (UEC)
- Irene Marcos-Araneta alleged a trust: Benedicto held 65% of FEMII and UEC shares for her benefit; trustees refused reconveyance demand
- March 2000: Irene sued for reconveyance of shares, accounting, and receivership in two civil cases before RTC Batac, Ilocos Norte; sought TRO
- Respondent Francisca Benedicto-Paulino moved to dismiss Case No. 3341-17; Benedicto adopted grounds in Case No. 3342-17
- Grounds included: SEC jurisdiction over intra-corporate disputes; improper venue; failure to allege trust acceptance
- RTC dismissed both complaints (venue impropriety; real action character); Irene moved for reconsideration and filed amended complaint naming Daniel Rubio, Orlando G. Reslin, Jose G. Reslin as co-plaintiffs/trustees
- RTC admitted amended complaint (Oct. 9, 2000), denied motions to dismiss (Dec. 18, 2000) and reconsideration (Mar. 15, 2001)
- Respondents sought and secured CA injunction then secured CA decision nullifying RTC