Saraza v. Francisco
G.R. No. 198718 – Nov. 27, 2013
First Division | J. Reyes
Digest Author: Mozo, Miguel
Topic: Jurisdiction of Courts – Incapable/Capable of Pecuniary Estimate
Case Summary:
Par. 1 – Facts
Upon full payment by respondent Francisco, the petitioners agreed to execute a Deed of Absolute Sale and to deliver
to the respondent the Owner’s Copy of the Transfer Certificate of Title no. 220530 of a subject property located in
Makati. When the full payment was made and the petitioners refused to perform their correlative obligation, the
respondent instituted a civil case for sum of money, specific performance and damages with the RTC of Imus, Cavite,
where the latter resides.
Par. 2 - Case Trail - MTC/RTC/CA + arguments
The RTC rendered a decision in favor of the respondent. The Court of Appeals affirmed the ruling of the RTC. Both
the RTC and the CA have determined that there has been a full payment by the respondent of his obligation under
the Agreement. Hence, a petition for review on Certiorari under Rule 45 of the Rules of Court which assails the
decision of the CA was submitted to this Court.
Par. 3 - Relevant Issue + SC Held
The issue is WoN the filing of this case with the RTC of Imus was proper and the Supreme Court ruled in the
affirmative.
Section 2, Rule 4 of the Rules of Court governs the venue for the respondent's action. It provides that personal actions
"may be commenced and tried where the plaintiff or any of the principal plaintiffs resides, or where the defendant or
any of the principal defendants resides, or in the case of a non-resident defendant where he may be found, at the
election of the plaintiff." Considering the respondent's statement in his complaint that he resides in Imus, Cavite, the
filing of his case with the RTC of Imus was proper.
Doctrines/Laws Involved:
Section 2, Rule 4 of the Rules of Court governs the venue for the respondent's action. It provides that personal actions
"may be commenced and tried where the plaintiff or any of the principal plaintiffs resides, or where the defendant or
any of the principal defendants resides, or in the case of a non-resident defendant where he may be found, at the
election of the plaintiff."