In Infante v. Aran Builders, Inc., the Supreme Court clarified the proper venue for an action to revive a judgment, holding that if the original judgment involved title to or possession of real property, the revival action is considered a real action and must be filed in the location of the property. This decision emphasizes that the nature of the original action dictates the venue for its revival, ensuring that disputes over real estate are resolved in the jurisdiction where the property is situated. The ruling provides essential guidance for legal practitioners on where to file actions to enforce judgments affecting real property.

From Makati to Muntinlupa: Where Does Justice Reside in Real Property Disputes?

The case originated from a complaint filed by Aran Builders, Inc. against Adelaida Infante seeking the revival of a judgment previously rendered by the Regional Trial Court (RTC) of Makati City. The original case involved specific performance and damages related to a property located in Muntinlupa City. The Makati RTC had ordered Infante to execute a deed of sale for the property in favor of Aran Builders. When Aran Builders sought to revive the judgment, they filed the action in the RTC of Muntinlupa City, leading Infante to file a motion to dismiss, arguing that the venue was improperly laid. Infante contended that the action for revival of judgment was a personal action and should have been filed in either Makati City or Parañaque City, where the parties resided.

The core issue before the Supreme Court was determining the proper venue for the action to revive the judgment. The Court needed to clarify whether such an action is considered a real action, which must be filed where the property is located, or a personal action, which can be filed where either party resides. The Court of Appeals (CA) had previously ruled in favor of Aran Builders, holding that the action was in rem because it involved title to or possession of real property, thus the Muntinlupa RTC was the proper venue. This decision was appealed to the Supreme Court, leading to the present ruling.

The Supreme Court began its analysis by examining Section 6, Rule 39 of the 1997 Rules of Civil Procedure, which governs the enforcement of judgments. While the rule allows for enforcement by action after five years from the entry of judgment, it does not specify the court in which the revival action should be filed. The Court referenced Aldeguer v. Gemelo, which stated that an action upon a judgment should be brought in the court where the judgment was rendered, or where the plaintiff or defendant resides, or in any other place designated by the statutes.

However, the Supreme Court emphasized that the rules on venue for actions in general must also be considered. Sections 1 and 2 of Rule 4 of the Rules of Court provide the framework for determining venue:

Section 1. Venue of real actions. – Actions affecting title to or possession of real property, or interest therein, shall be commenced and tried in the proper court which has jurisdiction over the area wherein the real property involved, or a portion thereof, is situated.

Section 2. Venue of personal actions. – All other 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.

Thus, the classification of the action as either real or personal is critical in determining the correct venue.

Infante argued that the action for revival of judgment was a personal action, relying on statements from Aldeguer v. Gemelo and Donnelly v. Court of First Instance of Manila. However, the Supreme Court distinguished these cases, noting that in Aldeguer, the judgment sought to be revived was for damages, not involving any real property. The Court clarified:

[t]he action for the execution of a judgment for damages is a personal one, and under section 377 [of the Code of Civil Procedure], it should be brought in any province where the plaintiff or the defendant resides, at the election of the plaintiff.

This distinction was crucial because the original judgment in Infante v. Aran Builders, Inc. directly involved real property.

Similarly, in Donnelly, the Court stated that an action to revive a judgment is a personal one. However, the Supreme Court clarified that this statement was an obiter dictum and not binding, as the issue of whether the action was quasi in rem was not properly before the Court. Moreover, the judgment in Donnelly also involved a sum of money, not real property. Therefore, the Supreme Court concluded that the classifications in Aldeguer and Donnelly did not apply to the present case.

The Supreme Court emphasized that the allegations in the complaint for revival of judgment determine whether it is a real or personal action. In this case, the complaint alleged that the final judgment ordered Infante to execute a deed of sale for a parcel of land in favor of Aran Builders, pay pertinent taxes, and register the deed of sale. Because the previous judgment conclusively declared Aran Builders’ right to have the title to the property conveyed to them, the action to revive the judgment was directly related to protecting this established interest in real property.

The Court held that the action fell under the category of a real action because it affected Aran Builders’ interest in the real property. This determination aligned with Section 1 of Rule 4, which mandates that actions affecting title to or possession of real property must be filed in the location of the property. Consequently, the Muntinlupa RTC was the proper venue for the action to revive the judgment.

Furthermore, the Supreme Court addressed the territorial jurisdiction of the RTC branches. Section 18 of Batas Pambansa Bilang 129 provides:

Sec. 18. Authority to define territory appurtenant to each branch. – The Supreme Court shall define the territory over which a branch of the Regional Trial Court shall exercise its authority. The territory thus defined shall be deemed to be the territorial area of the branch concerned for purposes of determining the venue of all suits, proceedings or actions, whether civil or criminal, as well as determining the Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts over which the said branch may exercise appellate jurisdiction.

This section makes it clear that each RTC branch has authority only over a specific territory defined by the Supreme Court. Originally, Muntinlupa City fell under the jurisdiction of the Makati Courts. However, with the enactment of Republic Act No. 7154, a branch of the RTC was established in Muntinlupa, granting it territorial jurisdiction over real property within the city.

The Supreme Court concluded that the Muntinlupa RTC did not commit grave abuse of discretion in denying Infante’s motion to dismiss. The CA’s decision affirming this denial was upheld, reinforcing the principle that actions to revive judgments affecting real property must be filed in the location of the property. This ruling provides clear guidance for determining the proper venue in such cases, ensuring that the interests of justice are served by resolving property-related disputes in the appropriate jurisdiction.

FAQs

What was the key issue in this case?	The key issue was determining the proper venue for an action to revive a judgment when the original judgment involved real property. The Court had to decide whether such an action is a real action or a personal action.
What is the difference between a real action and a personal action?	A real action affects title to or possession of real property, or interest therein, and must be filed where the property is located. A personal action does not involve real property and can be filed where either the plaintiff or defendant resides.
Why did the petitioner argue that the venue was improper?	The petitioner argued that the action for revival of judgment was a personal action and should have been filed in either Makati City or Parañaque City, where the parties resided, not in Muntinlupa City where the property is located.
What did the Court of Appeals decide?	The Court of Appeals ruled that the action was in rem because it involved title to or possession of real property, and therefore, the Muntinlupa RTC was the proper venue.
How did the Supreme Court distinguish previous cases cited by the petitioner?	The Supreme Court distinguished Aldeguer v. Gemelo and Donnelly v. Court of First Instance of Manila by noting that those cases involved judgments for damages or sums of money, not real property, making them personal actions.
What is the significance of Section 18 of Batas Pambansa Bilang 129?	Section 18 authorizes the Supreme Court to define the territory over which each branch of the Regional Trial Court exercises its authority, determining the venue for all suits, proceedings, and actions.
What was the final ruling of the Supreme Court?	The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, holding that the Muntinlupa RTC was the proper venue for the action to revive the judgment because it involved real property located in Muntinlupa City.
What is the practical implication of this ruling?	This ruling clarifies that actions to revive judgments affecting real property must be filed in the location of the property, providing clear guidance for legal practitioners and ensuring disputes are resolved in the appropriate jurisdiction.

The Supreme Court’s decision in Infante v. Aran Builders, Inc. provides a clear framework for determining the proper venue for actions to revive judgments, particularly when real property interests are involved. By emphasizing the nature of the original action and the location of the property, the Court ensures that such disputes are resolved in the appropriate jurisdiction, thereby upholding the principles of fairness and efficiency in legal proceedings.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Infante v. Aran Builders, Inc., G.R. No. 156596, August 24, 2007