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[130] UNION BANK OF THE PHILIPPINES V. MAUNLAD HOMES INC.  RTC affirmed the MeTC decision.

 RTC affirmed the MeTC decision. RTC noted that the property is located in
GR No. 190071 | August 15, 2012 | Brion, J. | Venue Malolos, Bulacan, but the ejectment suit was filed by Union Bank in Makati City,
based on the contract stipulation that “[t]he venue of all suits and actions arising
out or in connection with [the] Contract to Sell shall be [in] Makati City.”
NATURE OF THE CASE: Petition for review on certiorari of a decision of the CA
 The RTC ruled that the proper venue for the ejectment action is in Malolos,
Bulacan, pursuant to the second paragraph of Section 1, Rule 4 of the Rules of
CASE SUMMARY: An action for unlawful detainer was instituted against Maunlad Court. The RTC declared that Union Bank cannot rely on the waiver of venue
Homes by Union Bank. Maunlad Homes questions the propriety of the venue of Union provision in the contract because ejectment is not an action arising out of or
Bank’s unlawful detainer action which was filed in Makati City while the contested connected with the contract.
property is located in Malolos, Bulacan. Citing Section 1, Rule 4 of the Rules of Court,  Union Bank appealed the RTC decision to the CA through a petition for review
Maunlad Homes claimed that the unlawful detainer action should have been filed with under Rule 42 of the Rules of Court.
the municipal trial court of the municipality or city where the real property involved is  The CA affirmed the RTC decision. The CA determined that Union Bank’s cause
situated. Union Bank, on the other hand, justified the filing of the complaint with the of action is premised on the interpretation and enforcement of the contract and the
MeTC of Makati City on the venue stipulation in the contract which states that “[t]he determination of the validity of the rescission, both of which are matters beyond
venue of all suits and actions arising out [of] or in connection with this Contract to Sell the jurisdiction of the MeTC. Therefore, it ruled that the dismissal of the ejectment
shall be at Makati City.” The Supreme Court held that Union Bank rightfully filed the suit was proper. CA, however, made no further ruling on the issue of venue of the
complaint with the MeTC of Makati City. SC ruled the validity of a stipulation in a action.
contract providing for a venue for ejectment actions other than that stated in the Rules  From the CA’s judgment, Union Bank appealed to the Court by filing the present
of Court. petition for review on certiorari under Rule 45 of the Rules of Court.

DOCTRINE: While Section 1, Rule 4 of the Rules of Court states that ejectment ISSUE and RULING:
actions shall be filed in “the municipal trial court of the municipality or city wherein the
Whether or not the unlawful detainer action was filed correctly (YES)
real property involved x x x is situated[,]” Section 4 of the same Rule provides that the
rule shall not apply “[w]here the parties have validly agreed in writing before the filing  While Section 1, Rule 4 of the Rules of Court states that ejectment actions shall
of the action on the exclusive venue thereof.” Precisely, in this case, the parties be filed in “the municipal trial court of the municipality or city wherein the real
provided for a different venue. In Villanueva v. Judge Mosqueda, etc., et al., 115 property involved x x x is situated[,]” Section 4 of the same Rule provides that the
SCRA 904 (1982), the Court upheld the validity of a stipulation in a contract providing rule shall not apply “[w]here the parties have validly agreed in writing before the
for a venue for ejectment actions other than that stated in the Rules of Court. Since filing of the action on the exclusive venue thereof.” Precisely, in this case, the
the unlawful detainer action is connected with the contract, Union Bank rightfully filed parties provided for a different venue. In Villanueva v. Judge Mosqueda, etc., et
the complaint with the MeTC of Makati City. al., the Court upheld the validity of a stipulation in a contract providing for a venue
for ejectment actions other than that stated in the Rules of Court. Since the
unlawful detainer action is connected with the contract, Union Bank rightfully filed
FACTS: the complaint with the MeTC of Makati City.
 Union Bank, as seller, and respondent Maunlad Homes, Inc., as buyer, entered
into a contract to sell involving the Maunlad Shopping Mall. Part of the purchase
price was to be paid by Maunlad Homes as down payment, with the balance to be
amortized over the succeeding 180- month period. DISPOSITIVE: WHEREFORE, we hereby GRANT the petition and SET ASIDE the
 When Maunlad Homes failed to pay despite Union Bank’s repeated demands, an decision dated October 28, 2009 of the Court of Appeals in CA-G.R. SP No. 107772.
ejectment suit was instituted by Union Bank before the Metropolitan Trial Court of Respondent Maunlad Homes, Inc. is ORDERED TO VACATE the Maunlad Shopping
Makati City. Maunlad Homes resisted the suit by claiming, among others, that it is Mall, the property subject of the case, immediately upon the finality of this Decision.
the owner of the property as Union Bank did not reserve ownership of the property Respondent Maunlad Homes, Inc. is further ORDERED TO PAY the rentals-in-
under the terms of the contract. arrears, as well as rentals accruing in the interim until it vacates the property.

PROCEDURAL HISTORY: The case is REMANDED to the Metropolitan Trial Court of Makati City, Branch 64, to
determine the amount of rentals due. In addition to the amount determined as unpaid
 MeTC dismissed Union Bank’s ejectment complaint. It found that Union Bank’s rent, respondent Maunlad Homes, Inc. is ORDERED TO PAY legal interest of six
cause of action was based on a breach of contract and that both parties are percent (6o/o) per annum, from November 19, 2003, when the demand to pay and to
claiming a better right to possess the property based on their respective claims of vacate was made, up to the finality of this Decision. Thereafter, an interest of twelve
ownership of the property. percent ( 12%) per annum shall be imposed on the total amount due until full payment
 MeTC ruled that the appropriate action to resolve these conflicting claims was an is made.
accion reivindicatoria, over which it had no jurisdiction.

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