FACTS:

Respondent Sarmiento Enterprises filed a complaint against petitioner Atlas Developer and Steel Industries for collection of the sum of P8,076 for the cost of steel bars and MS plates purchased. Petitioner filed a motion to dismiss the complaint on the ground of improper venue because of a stipulation in the sales invoice stating that the parties submit to the jurisdiction of the Court of the City of Manila if legal action is resorted to enforce collection of the account. The motion was denied by the trial court and the subsequent motion for reconsideration was also denied. Hence, petitioner filed a petition for certiorari before the Supreme Court.

ISSUES:

1. Whether the venue of the action was properly laid in the Court of First Instance at Pasig, Metro Manila.

RULING:

1. The Supreme Court ruled that the venue of the action was improperly laid in the Court of First Instance at Pasig, Metro Manila. The stipulation in the sales invoice regarding jurisdiction was interpreted by the court as pertaining to venue and not jurisdiction. Jurisdiction over an action is conferred by law and cannot be changed by mere agreement of the parties. The trial court erred in ruling that the Regional Trial Court of Pasig had jurisdiction over the claim because the amount involved did not exceed the minimum jurisdictional limit for a money claim in the Regional Trial Court, which is P20,000. Therefore, the complaint in the Regional Trial Court was dismissed without prejudice to the plaintiff filing it in the proper inferior court.