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	GR No. 170281 2008-01-18	REPUBLIC v. GLASGOW CREDIT CORONA, J.
But inasmuch as Glasgow never questioned the venue of the Republic's complaint for civil forfeiture against it, how could the trial court have dismissed the complaint for improper venue? In Dacoycoy v. Intermediate Appellate Court[6] (reiterated in Rudolf Lietz Holdings, Inc. v. Registry of Deeds of Parañaque City),[7] this Court ruled:The motu proprio dismissal of petitioner's complaint by [the] trial court on the ground of improper venue is plain error.... (emphasis supplied)
	GR NO. 154338 2007-10-05	UNIVERSAL ROBINA CORPORATION v. ALBERT LIM SANDOVAL-GUTIERREZ, J.
In Dacoycoy v. Intermediate Appellate Court,[9] this Court held that a trial court may not motu proprio dismiss a complaint on the ground of improper venue, thus:Dismissing the complaint on the ground of improper venue is certainly not the appropriate course of action at this stage of the proceedings, particularly as venue, in inferior courts as well as in the courts of first instance (now RTC), may be waived expressly or impliedly. Where the defendant fails to challenge timely the venue in a motion to dismiss as provided by Section 4 of Rule 4 of the Rules of Court, and allows the trial to be held and a decision to be rendered, he cannot on appeal or in a special action be permitted to belatedly challenge the wrong venue, which is deemed waived.