- Petitioner
- Agustin Asencio
- Respondent
- Francisco Gutierrez
- Citation
- G.R. No. 100
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Willard, J.
- Decided
- September 9, 1901
Summary
This 1901 Supreme Court case established important precedent on proper venue for contract disputes. Plaintiff Asencio sought to collect rent from defendant Gutierrez for a printing machine that remained in Asencio's Iloilo property after their lease expired. The central issue was whether the case should be tried in Iloilo (where the property was located) or Manila (where Gutierrez had relocated). The Supreme Court affirmed that Manila was proper venue, applying Civil Code provisions that require payment at the debtor's residence when no specific payment location is stipulated. The decision clarified the distinction between personal contract actions and real property actions regarding venue rules, establishing that a debtor's change of residence determines jurisdiction for personal obligations under the Civil Code.