SC rejects Irene Marcos’ suit vs Benedictos over court venue
By Leila Salaverria
Philippine Daily Inquirer
First Posted 22:23:00 08/27/2008
Filed Under: Laws, Judiciary (system of justice)
MANILA, Philippines -- The Supreme Court has turned down the plea of Irene Marcos Araneta, daughter of the late dictator Ferdinand Marcos, to revive a civil case to recover her shares in two companies that were allegedly held in her name by a crony of her father.
The high court said she brought the case before the wrong venue, as it upheld a Court of Appeals ruling that stated that Araneta's civil case against Roberto Benedicto, who has since been replaced in the case by his wife Julita after his death, and daughter Francisca, should be dismissed.
The tribunal pointed out that Araneta was a resident of Forbes Park, Makati City, but filed the civil case before the Batac, Ilocos Norte regional trial court.
"The Court will not speculate on the reason why petitioner Irene, for all the inconvenience and expense she and her adversaries would have to endure by a Batac trial, preferred that her case be heard and decided by the RTC in Batac," it said in an August 22 decision penned by Justice Presbitero Velasco.
It added that those filing cases should only rely on the merits of their case in seeking victory in the courts.
"Litigants ought to bank on the righteousness of their causes, the superiority of their cases, and the persuasiveness of arguments to secure a favorable verdict. It is high time that courts, judges, and those who come to court for redress keep this ideal in mind," it said.
Araneta filed the case against Benedicto and his associates to recover the 65 percent of her stockholdings in the Far East Managers and Investors Inc. and the Universal Equity Corporation, which she said they only held in trust for her.
The Benedicto group refused to reconvey the 65 percent stockholdings to her. The two companies were organized in 1968 and 1972.
The Batac RTC initially dismissed Araneta's case since she was not an Ilocos Norte resident, but she contested this ruling via a motion for reconsideration and also filed an amended complaint adding new complainants to the case whom she said were her trustees.
These trustees were all residents of Batac, Ilocos Norte. The RTC subsequently denied Araneta's motion for reconsideration but admitted her amended complaint.
On the petition of the Benedictos, the Court of Appeals reversed the RTC decision and dismissed the amended complaint of Araneta.
Araneta then brought the case to the Supreme Court. In its decision, the high court upheld the appellate court decision but cited a different reason for dismissing Araneta's case.
It agreed with Araneta that the appellate court should not have delved into the merits of her civil case and should just have confined itself to determining whether the Batac court had jurisdiction over the issue.
It also sided with her when she said the appellate court erred in ruling that her amended complaint should not have been admitted. It said she had a right to amend her complaint because when she filed this, her original complaint had not been decided upon with finality.
But the high court also said that the RTC found that Araneta was not a Batac resident when the questioned actions took place.
It said Araneta could not opt for Batac as the venue for her reconveyance complaint, and added that the community tax certificate she presented was not enough proof that she lived in the Ilocos Norte province, considering that such a document was easy to obtain and one could dictate what would be printed there.
It also said that since Araneta was the principal in the case, her inclusion of additional complainants who were Batac residents would not cure the defect. It pointed out that the rules stated that a venue for a case would be determined by the residence of the principal party.
It also said the additional complainants, who were her "trustees," could only prosecute the case on Araneta's behalf.
"In the final analysis, the residences of Irene's co-plaintiffs cannot be made the basis in determining the venue of the subject suit. This conclusion becomes all the more forceful considering that Irene herself initiated and was actively prosecuting her claim against Benedicto, his heirs, assigns, or associates, virtually rendering the impleading of the trustees unnecessary," it said.
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