Case Summary (G.R. No. L-32217)
Relevant Dates
The events pertinent to this case occurred primarily in 1970, with the initial complaint filed on April 22, 1970, and subsequent motions and orders issued throughout June 1970. The decision of the Supreme Court was rendered on August 15, 1988.
Applicable Law
This case is governed by the 1987 Philippine Constitution and relevant provisions of the Revised Rules of Court, particularly Section 3, Rule 4, which addresses the venue of actions.
Factual Background
On October 25, 1969, Mercedes Sy purchased rice from M. Chuakay & Sons Rice Mill, Inc., and in the ensuing legal action, the Municipal Court issued a writ of attachment due to dishonored checks provided by Sy. After various motions regarding the dismissal of the complaint and the writ of attachment, the Municipal Court denied Sy's motion, prompting her to seek a higher judicial remedy.
Issues Presented
The petitioner raised two crucial issues: (1) whether the Municipal Court of Cabatuan, Isabela is the proper venue for the case considering the unsigned nature of the sales invoice receipt; and (2) whether the sales invoice receipt can affect the venue of the action per the provisions of the Revised Rules of Court.
Venue Determination
The Supreme Court determined that the sales invoice receipt, despite being unsigned, contained a stipulation indicating that the buyer agreed to the jurisdiction of Cabatuan, Isabela courts in cases of default. This stipulation was found to be a sufficient basis for establishing jurisdiction. The petitioner’s argument that the lack of signature invalidated the invoice was dismissed, citing precedent which holds that acceptance of the sales invoice constitutes implied conformity to its terms.
Legal Precedent
The Court referenced prior cases, specifically Pan Pacific Company (Phil.) vs. Advertising Corporation and Naga Development v. Court of Appeals, both of which affirmed that actions undertaken by a party, such
...continue readingCase Syllabus (G.R. No. L-32217)
Case Background
- This case involves a petition for prohibition and certiorari, including a request for a preliminary injunction, aimed at overturning a June 17, 1970 Order from the Municipal Court of Cabatuan, Isabela.
- The case originated from Civil Case No. 298, initiated by the private respondent, M. Chuakay & Sons Rice Mill, Inc., against petitioner Mercedes Sy.
- The complaint alleges that on October 25, 1969, the petitioner purchased 180 cavans of rice valued at P8,560.00 and agreed to jurisdiction in Isabela courts for any arising disputes.
- Payment was attempted via post-dated checks, both of which were dishonored, leading the private respondent to seek a writ of preliminary attachment against the petitioner’s properties.
Procedural History
- The respondent judge issued a writ of attachment on April 25, 1970, following the filing of the complaint.
- The petitioner filed a Motion to Dismiss the complaint on June 10, 1970, arguing improper venue and citing an existing criminal charge of estafa against her.
- The private respondent countered that the petitioner had waived her right to venue based on the Sales I