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THEODORE v. SPS. ALAN

FACTS:

Spouses Alan and Em Ang obtained a loan from Theodore and Nancy Ang. The loan was not paid despite repeated demands. The petitioners sent a demand letter to the respondents requesting payment of the outstanding debt. The respondents still failed to settle their loan obligation. The petitioners, who were residing in Los Angeles, California, executed Special Powers of Attorney in favor of Attorney Eldrige Marvin B. Aceron for the purpose of filing a complaint against the respondents. A complaint for collection of sum of money was filed by Atty. Aceron on behalf of the petitioners in the RTC of Quezon City. The respondents moved for the dismissal of the complaint on the grounds of improper venue and prescription. The RTC denied the motion to dismiss, ruling that the venue was proper based on the address of Atty. Aceron who was the plaintiff's attorney-in-fact. The respondents sought reconsideration but was denied by the RTC. The respondents then filed a petition for certiorari with the Court of Appeals (CA) claiming that the complaint should have been filed in the RTC of Bacolod City since the petitioners reside in Los Angeles, California, USA. The CA annulled and set aside the RTC orders and ordered the dismissal of the complaint, ruling that the case should have been filed in Bacolod City where the defendants reside. The petitioners sought reconsideration but was denied by the CA. Hence, this petition for review on certiorari.

ISSUES:

  1. Can the petitioners file their complaint for collection of sum of money in the RTC of Quezon City?

  2. Is the residence of Atty. Aceron, the attorney-in-fact of the petitioners, material to the determination of venue?

  3. Whether or not the attorney-in-fact can be considered a real party in interest in a case.

RULING:

  1. No, the petitioners cannot file their complaint for collection of sum of money in the RTC of Quezon City. The complaint should have been filed in the RTC of Bacolod City, the court of the place where the respondents reside.

  2. No, the residence of Atty. Aceron is immaterial to the determination of venue. Atty. Aceron is not a real party in interest in the case and does not stand to be benefited or injured by any judgment therein.

  3. The attorney-in-fact is not considered a real party in interest in a case.

PRINCIPLES:

  • The rules on the venue of personal actions are fixed for the convenience of the plaintiffs and their witnesses.

  • Choosing the venue of an action is not left to a plaintiff's caprice; it is regulated by the Rules of Court.

  • In personal actions, the plaintiff has the option to file the complaint in the place where he himself or any of the defendants resides.

  • If the plaintiff does not reside in the Philippines, the complaint may only be filed in the court of the place where the defendant resides.

  • The situs for bringing real and personal civil actions is fixed by the Rules of Court to attain convenience for the litigants and witnesses.

  • Atty. Aceron, as the attorney-in-fact of the petitioners, is not a real party in interest unless he stands to be benefited or injured by the judgment in the suit.

  • Interest within the meaning of the Rules of Court means material interest or an interest in issue to be affected by the decree or judgment of the case.

  • An attorney-in-fact is not a real party in interest. Only the beneficiaries or persons being represented are deemed the real party in interest.

  • The rules on venue are designed to ensure a just and orderly administration of justice and should not be left to the plaintiff's whim or caprice.

  • When a statute is clear, plain, and free from ambiguity, it must be given its literal meaning and applied without interpretation.