San Miguel Corporation v.

Monasterio
Rule 4, Sec 4

Facts:
San Miguel Corporation [SMC] entered into an Exclusive Warehouse Agreement [EWA] with SMB
Warehousing services, represented by its manager Monasterio, wherein SMB would provide the
necessary services for the storage and warehousing of SMC products.

The EWA also contained a stipulation on the venue of actions: Should it be necessary that an action be
brought in court to enforce the terms of this Agreement or the duties or rights of the parties herein, it is
agreed that the proper court should be in the courts of Makati or Pasig, Metro Manila, to the exclusion
of the other courts at the option of the COMPANY.

In 1998, Monasterio [a resident of Naga City] filed a complaint for collection of sum of money against SMC
before the RTC-Naga City. He alleged that he was not paid 900k for the services he rendered as a cashier.

SMC filed a Motion to Dismiss on the ground of improper venue. It argued that the money claim arose
from Monasterios services as a warehouse contractor, thus the EWA stipulation would apply [citing Sec
4b in relation to Sec 2, Rule 4].

Issue: W/N the filing of the case before RTC Naga was proper?

Ruling: Yes.

Exclusive venue stipulation embodied in a contract restricts or confines parties thereto when the suit
relates to breach of the said contract. Monasterios cause of action was not based on the EWA. The
cashiering service was different from his functions as a warehouse contractor, and the EWA would not
apply.

The collection for money, being a personal action, it was properly filed before the RTC Naga City where
Monasterio resides.