Short answer. Only in the Supreme Court, the Court of Appeals, or the Regional Trial Court with jurisdiction over the area where the respondent resides; if the Solicitor General commences the action, it may instead be filed in a Manila Regional Trial Court, the Court of Appeals, or the Supreme Court.
What the law says
An action under the preceding six sections can be brought only in the Supreme Court, the Court of Appeals, or in the Regional Trial Court exercising jurisdiction over the territorial area where the respondent or any of the respondents resides, but when the Solicitor General commences the action, it may be brought in a Regional Trial Court in the City of Manila, in the Court of Appeals, or in the Supreme Court.
Rule 66, Section 7 — Venue. Read the full provision →
The general venue rule
For quo warranto actions covered by the preceding six sections, venue is limited to three courts: the Supreme Court, the Court of Appeals, or the Regional Trial Court exercising jurisdiction over the territorial area where the respondent, or any of the respondents if there are several, resides. This three-court menu is exhaustive for an ordinary quo warranto action; a petitioner cannot simply file in whichever Regional Trial Court happens to be most convenient if it does not have jurisdiction over the respondent's actual residence. A petitioner planning to sue several respondents who reside in different places would need to think carefully about which of them anchors the proper venue for the whole case.
A special option when the Solicitor General files
When the Solicitor General is the one commencing the action, an additional option opens up: the case may instead be brought in a Regional Trial Court in the City of Manila, in the Court of Appeals, or in the Supreme Court, regardless of where the respondent actually resides. This Manila-based option spares the Solicitor General's office from having to litigate in whatever province or region a particular respondent happens to live in at the time. It also means the choice of forum in a government-initiated quo warranto case can turn on a strategic decision by the Solicitor General's office rather than on the respondent's address.
Why the venue choice matters
This gives the Solicitor General more flexibility in choosing where to litigate compared to a private relator or public prosecutor, who are tied to the respondent's residence for the Regional Trial Court option. A petitioner should confirm who is actually commencing the action before assuming which courts are available, since filing in the wrong venue could expose the case to a motion to dismiss for improper venue. Understanding whose action it actually is can therefore change which courts are even open to hearing the case in the first place.
Related provisions
- Rule 66, Section 7 — Venue
- Rule 66, Section 1 — Action by Government against individuals
- Rule 66, Section 3 — When Solicitor General or public prosecutor may commence action with permission of court