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    Puyat vs. Zabarte PDF

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    Jona Calibuso
    The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that forum non-conveniens is not a valid ground for a local court to refuse jurisdiction over a case seeking enforcement of a foreign judgment. Forum non-conveniens allows a court to decline jurisdiction for convenience and fairness reasons, but is not applicable in cases where a party simply seeks to enforce a already-decided foreign judgment. The RTC properly exercised its jurisdiction over the respondent's action to enforce a money judgment issued by a California court against the petitioner.

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    Puyat vs. Zabarte PDF

    Uploaded by

    Jona Calibuso
    64 views2 pages
    The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that forum non-conveniens is not a valid ground for a local court to refuse jurisdiction over a case seeking enforcement of a foreign judgment. Forum non-conveniens allows a court to decline jurisdiction for convenience and fairness reasons, but is not applicable in cases where a party simply seeks to enforce a already-decided foreign judgment. The RTC properly exercised its jurisdiction over the respondent's action to enforce a money judgment issued by a California court against the petitioner.

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    6. Puyat vs. Zabarte.pdf

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    The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that forum non-conveniens is not a valid ground for a local court to refuse jurisdiction over a case seeking enforcement of a foreign judgment. Forum non-conveniens allows a court to decline jurisdiction for convenience and fairness reasons, but is not applicable in cases where a party simply seeks to enforce a already-decided foreign judgment. The RTC properly exercised its jurisdiction over the respondent's action to enforce a money judgment issued by a California court against the petitioner.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    64 views2 pages

    Puyat vs. Zabarte PDF

    Uploaded by

    Jona Calibuso
    The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that forum non-conveniens is not a valid ground for a local court to refuse jurisdiction over a case seeking enforcement of a foreign judgment. Forum non-conveniens allows a court to decline jurisdiction for convenience and fairness reasons, but is not applicable in cases where a party simply seeks to enforce a already-decided foreign judgment. The RTC properly exercised its jurisdiction over the respondent's action to enforce a money judgment issued by a California court against the petitioner.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    GIL MIGUEL T. PUYAT, petitioner, vs. RON ZABARTE, respondent.

    G.R. No. 141536. February 26, 2001

    Forum non-conveniens is not a ground to divest a local court of its jurisdiction in actions for enforcement
    of foreign judgment. (EH KASI, ANG FORUM NON-CONVENIENS IS DISCRETIONARY UPON THE COURT
    AND IS PREMISED ON THE PECULIARITY OF THE FACTS THAT WOULD WARRANT THE COURT TO RULE
    THAT IT IS NOT THE MOST CONVENIENT FORUM, eh dito, wala naman nang icoconsider na facts since
    ENFORCEMENT LNG NG LAW ALREADY ADJUDGED BY A FOREIGN COURT. )

    NATURE OF THE CASE: PETITION for review on certiorari of a decision of the Court of Appeals.

    SC DECISION: WHEREFORE, the Petition is hereby DENIED and the assailed DECISION and Resolution
    AFFIRMED.

    FACTS:

    o Respondent Ron Zabarte commenced an action before the RTC to enforce the money judgment
    rendered by the Superior Court for the State of California against the herein petitioner.
    o The RTC granted the same and ordered the petitioner to pay the respondent.

    o Petitioner appealed it to the CA. Petitioner argues that the RTC should have refused to entertain
    the Complaint for enforcement of the foreign judgment on the principle of forum non
    conveniens. He claims that the trial court had no jurisdiction, because the case involved
    partnership interest, and there was difficulty in ascertaining the applicable law in California. All
    the aspects of the transaction took place in a foreign country, and respondent is not even
    Filipino.

    o The CA denied the same and it reasoned out that the recognition of the foreign judgment was
    based on comity, reciprocity and res judicata.

    o Hence, this petition.

    ISSUE: WON the RTC should refuse to enforce a foreign judgment on the ground of forum non-
    conveniens. (NO)

    RULING: NO. The RTC is a convenient forum. It has jurisdiction to enforce a foreign judgment.

    The Court held that the following are only reasons why local courts should refuse to impose
    their jurisdiction over cases involving conflict of laws:

    1. The belief that the matter can be better tried and decided elsewhere, either because the main
    aspects of the case transpired in a foreign jurisdiction or the material witnesses have their
    residence there;

    2. The belief that the non-resident plaintiff sought the forum, a practice known as forum shopping,
    merely to secure procedural advantages or to convey or harass the defendant;

    3. The unwillingness to extend local judicial facilities to nonresidents or aliens when the docket
    may already be overcrowded;
    4. The inadequacy of the local judicial machinery for effectuating the right sought to be
    maintained: and

    5. The difficulty of ascertaining foreign law.

    None of the aforementioned reasons barred the RTC from exercising its jurisdiction. In the present
    action, there was no more need for material witnesses, no forum shopping or harassment of petitioner,
    no inadequacy in the local machinery to enforce the foreign judgment, and no question raised as to the
    application of any foreign law.

    Authorities agree that the issue of whether a suit should be entertained or dismissed on the basis of
    the abovementioned principle depends largely upon the facts of each case and on the sound discretion
    of the trial court. Since the present action lodged in the RTC was for the enforcement of a foreign
    judgment, there was no need to ascertain the rights and the obligations of the parties based on foreign
    laws or contracts. The parties needed only to perform their obligations under the Compromise
    Agreement they had entered into.

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