**Facts:**
Warren Embes Luyaben, the respondent in this case, attended an auction held by Auction in Malinta, Inc. on May 29, 2001, where he emerged as the highest bidder for a wheel loader. On June 7, 2001, Luyaben made payment for the loader, but Auction in Malinta, Inc. failed to deliver the item, offering a replacement which was never received. Consequently, Luyaben filed a complaint for damages with the Regional Trial Court (RTC) of Bulanao, Tabuk, Kalinga, against Auction in Malinta, Inc., which is based in Malinta, Valenzuela City. The petitioner contested the venue as improper based on the agreement stipulating exclusive venue in Valenzuela City and moved for dismissal. The RTC ruled in favor of the petitioner, dismissing the case, but this decision was reversed by the Court of Appeals, prompting the petitioner to take the matter to the Supreme Court.
**Issues:**
1. Whether the stipulation in the parties’ Bidders Application and Registration Bidding Agreement effectively limited the venue of the case exclusively to the RTC of Valenzuela City.
**Court’s Decision:**
The Supreme Court ruled against the exclusivity of the venue stipulation, emphasizing that unless specific restrictive language is used in the agreement, the venue is not limited to the one specified. Drawing from the established doctrines in previous cases such as Polytrade Corporation v. Blanco and Unimasters Conglomeration, Inc. v. Court of Appeals, the Court held that the agreed venue in Valenzuela City was merely an additional forum, not an exclusive one. Consequently, the case for damages filed by Luyaben could legitimately be pursued in the RTC of Bulanao, Tabuk, Kalinga.
**Doctrine:**
The doctrine established reiterates that for an agreement on venue to be considered exclusive, there must be clear, categorical, and limiting language indicating the parties’ intention to restrict legal actions to a specific venue to the exclusion of others. Absent these qualifiers, the agreement should be interpreted as permissive, offering an additional option rather than limiting the venue dictated by the general rules of court.
**Class Notes:**
– Venue for Personal Actions: A plaintiff in a personal action may choose to file the case in the residence of either the plaintiff or the defendant, unless an agreement explicitly states otherwise using clear, restrictive language.
– Interpretation of Venue Agreements: In the absence of words like “exclusively,” “only,” or similar qualifiers, venue stipulations in agreements are not construed as limiting but as additional options.
– Legal Precedent on Venue Agreements: The case emphasizes the principles from Polytrade Corporation v. Blanco and Unimasters Conglomeration, Inc. v. Court of Appeals, underscoring the requirement for explicit language to restrict legal venue.
**Historical Background:**
This case reflects the evolving judicial approach to interpreting agreements on the venue of actions. Over the years, the Philippine Supreme Court has shifted from potentially accepting implied exclusive venues based on parties’ agreements to requiring unequivocal language to limit venue, emphasizing party autonomy while ensuring access to justice is not unduly restricted by private agreements. This case reiterates the judiciary’s commitment to clear interpretations of venue stipulations, highlighting the importance of explicit contractual language in determining the jurisdiction of legal actions.
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