Determine the principles applied in deciding the Case

Mere act of exporting from one's own country without doing specific commercial acts in importing country not doing business in the latter

B. Van Zuiden Bros. Ltd.

vs. GTVL Manufacturing Industries, Inc.

G.R. No. 147905, May 28, 2007

Facts:F Corporation, a Hong Kong corporation, sold on several occasions, lace products to P Corporation, a Philippine corporation. Upon instruction of P Corporation, F Corporation delivered the products to G Corporation, another Hong Kong corporation. The products were considered sold upon receipt by G Corporation. G Corporation, in turn, had the obligation to deliver the products to the Philippines. When P Corporation failed to pay its remaining balance to F Corporation, the latter filed an action for collection in the Philippines against the former. P Corporation sought the dismissal of the complaint on the ground that F Corporation could not sue in Philippine courts since it was doing business in the Philippines without a license.

Held:F Corporation was not doing business in the Philippines. While F Corporation and P Corporation entered into a series of transactions implying a continuity of commercial dealings, the perfection and consummation of these transactions were done outside the Philippines. In other words, the sale of the lace products was consummated in Hong Kong. No single activity was performed here in the Philippines by F Corporation pursuant to its purpose as a business organization. The mere act of exporting from one's own country, without doing any specific commercial act within the territory of the importing country, cannot be deemed as doing business in the importing country. Thus, since F Corporation was not doing business in the Philippines, it did not need a license in order to initiate and maintain a collection suit against P Corporation for the unpaid balance of the latter.

Direction:Determine the principles applied in the above case. Give your insights on the decision made by the Supreme Court.