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."