Case Summary (G.R. No. L-14352)
Applicable Laws and Venue
The legal framework governing this case includes the 1987 Philippine Constitution, the Civil Code, and the Rules of Court. Specifically, Rule 4, Section 2 of the Rules of Court pertains to the venue for personal actions, allowing the plaintiff to bring the case in the place of residence of either party or in a place agreed upon by both parties in their contract.
Factual Background
On August 1, 1993, San Miguel Corporation entered into an Exclusive Warehouse Agreement with SMB Warehousing Services, represented by respondent Monasterio. This agreement explicitly designated the exclusive venue for any actions to be in the courts of Makati or Pasig, Metro Manila. On November 3, 1998, Monasterio filed a complaint in Naga City, claiming P900,600 for unpaid cashiering fees arising from his services to SMC, which he argued were separate from the warehousing services outlined in the EWA.
Motion to Dismiss
San Miguel Corporation subsequently filed a Motion to Dismiss on November 19, 1998, citing improper venue based on the stipulation in the EWA. The company posited that Monasterio's claims were directly related to the terms of the contract, and thus, the case should be tried in the courts of Makati or Pasig. Conversely, Monasterio contended that the cashiering services constituted a separate agreement not covered by the EWA’s venue stipulation.
Regional Trial Court Ruling
On February 22, 1999, the RTC of Naga City denied SMC’s motion to dismiss. The court concluded that Monasterio's claim was based on services outside the EWA and thus could be tried in Naga City, where he resided. SMC’s subsequent Motion for Reconsideration was also denied, prompting SMC to elevate the matter to the Court of Appeals.
Court of Appeals Decision
The Court of Appeals, in its July 16, 2001 decision, upheld the RTC's ruling that Monasterio’s claims for cashiering services were inseparable from the warehousing services. Nonetheless, the appellate court determined that the case became moot and academic due to Monasterio’s filing of an amended complaint, which SMC had answered. SMC’s motion for reconsideration was denied, leading to SMC’s petition for certiorari.
Legal Issues Raised
The issues presented were whether the Supreme Court could review the Court of Appeals' finding regarding improper venue and whether the claim’s mootness was warranted due to the filing of an amended complaint. The Supreme Court focused on whether the RTC erred in its denial of SMC’s motion to dismiss and whether the appellate court’s ruling on mootness was correct.
Supreme Court's Analysis
The Supreme Court articulated that venue stipulations in contracts are generally mandatory unless they contradict public policy. It acknowledged that
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Case Overview
- The case involves an appeal by San Miguel Corporation (SMC) against the decision and resolution of the Court of Appeals regarding the denial of its motion to dismiss based on improper venue.
- The Regional Trial Court (RTC) of Naga City, Branch 20, had previously ruled that the venue for the case was appropriate, leading SMC to elevate the matter for review.
Background of the Case
- On August 1, 1993, SMC entered into an Exclusive Warehouse Agreement (EWA) with SMB Warehousing Services (SMB), represented by Troy Francis L. Monasterio.
- The EWA stipulated that any legal actions arising from the agreement should be filed in the courts of Makati or Pasig, Metro Manila.
- On November 3, 1998, Monasterio filed a complaint against SMC in the RTC of Naga City for the collection of P900,600, claiming unpaid cashiering fees for services rendered beyond the scope of the EWA.
Details of the Complaint
- Monasterio alleged that he assumed substantial financial responsibilities as a cashier at SMC’s sales offices, claiming unpaid fees for a period spanning from September 1993 to November 1997.
- He sought payment for warehousing fees, cashiering fees, exemplary damages, and attorney's fees.
Motion to Dismiss
- SMC filed a Motion to Dismiss on November 19, 1998, asserting that the cla