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ADELAIDA INFANTE v. ARAN BUILDERS

FACTS:

This case involves a Petition for Review on Certiorari seeking the reversal of the Decision of the Court of Appeals (CA) which upheld the Order of the Regional Trial Court of Muntinlupa City (RTC). The case before the RTC is an action for revival of judgment filed by Aran Builders, Inc. against Adelaida Infante. The judgment sought to be revived was rendered by the Regional Trial Court of Makati City in an action for specific performance and damages. The Makati RTC judgment decreed various actions to be done by Adelaida Infante within thirty (30) days, such as delivering complete plans, executing a deed of sale, paying taxes, securing written conformity, and registering the deed of sale. Petitioner filed a motion to dismiss the action for revival of judgment on the grounds of lack of jurisdiction and improper venue. The Muntinlupa RTC denied the motion, stating that cases involving properties located in Muntinlupa City are to be litigated before the Regional Trial Courts in Muntinlupa City. Petitioner's motion for reconsideration was also denied. Petitioner then filed a petition before the CA, claiming grave abuse of discretion and arguing that the action for revival of judgment is a personal action, and therefore the venue should be either Makati City or Parañaque City. The CA ruled in favor of the private respondent, stating that the action for revival of judgment is an action in rem and that the proper venue is where the real property is located. Petitioner moved for reconsideration, but it was denied. Hence, this petition. Petitioner argues that the action for revival of judgment is an action in personam and should be filed with the RTC of the place where petitioner or private respondent resides. Private respondent maintains that the action is a real action, and thus the venue is properly laid with the court of the place where the realty is located.

ISSUES:

  1. Whether the action for revival of judgment is a real action or a personal action.

  2. What is the proper venue for the action for revival of judgment?

  3. Whether the action for revival of judgment falls under the category of a real action.

  4. Whether the Regional Trial Court of Muntinlupa City had jurisdiction over the case.

RULING:

  1. The action for revival of judgment is a real action. The proper venue for a real action is the court of the place where the real property involved, or a portion thereof, is situated.

  2. The proper venue for the action for revival of judgment is the court of the place where the disputed property is located.

  3. The action for revival of judgment falls under the category of a real action. The purpose of the action is to enforce the private respondent's adjudged rights over a piece of real property, establishing their interest in the disputed property. Therefore, based on the nature of the action, it should be considered a real action.

  4. The Regional Trial Court of Muntinlupa City had jurisdiction over the case. Section 18 of Batas Pambansa Bilang 129 grants authority to the Regional Trial Court to define the territory over which a branch of the court exercises its jurisdiction. Since the creation of a branch of the Regional Trial Court in Muntinlupa City, that court has territorial jurisdiction over Muntinlupa City and can validly issue orders and processes concerning real property within that jurisdiction. Therefore, there was no grave abuse of discretion by the Regional Trial Court in denying the motion to dismiss and the Court of Appeals did not err in affirming the same.

PRINCIPLES:

  • Under the Rules of Court, the venue of real actions, which affect title to or possession of real property, is the court which has jurisdiction over the area wherein the real property involved is situated.

  • The venue of personal actions, on the other hand, may be commenced and tried where either the plaintiff or defendant resides, or in the case of a non-resident defendant, where he may be found, at the election of the plaintiff.

  • An action for revival of judgment falls under the category of a real action when it seeks to enforce adjudged rights over real property.

  • The territorial jurisdiction of a Regional Trial Court is defined by the Supreme Court, and a branch of the court exercises its jurisdiction only over the territory defined for it.