• This case clarifies the distinction between domestic and international arbitration and strictly reinforces the policy of judicial restraint in reviewing arbitral awards. After an arbitral tribunal ruled against Ramcar, Inc., the Regional Trial Court (RTC) and the Court of Appeals (CA) vacated parts of the award by re-evaluating its merits. The Supreme Court reversed this, ruling that the arbitration was international in nature and that the lower courts overstepped their authority. The Court held that courts cannot review the merits or correct errors of fact or law made by an arbitral tribunal, except on very limited grounds, such as when the tribunal rules on an issue not submitted to it.

• The Joint Venture: Ramcar, Inc. (a Philippine company) and Yuasa Battery Co., Ltd. (YBC, a Japanese company) entered into a Joint Venture Agreement (JVA) to form Oriental Yuasa Battery Corporation (OYBC) in the Philippines.
• The Non-Compete Clause: The JVA included a clause preventing either party or their successors from engaging in any competing battery business in the Philippines during the agreement and for two years after.
• Corporate Changes: YBC eventually became part of a new entity, GS Yuasa Corporation (GYC), whose international operations were handled by GS Yuasa International Ltd. (GYIL).
• Arbitration: In 2011, Ramcar initiated arbitration, claiming that GYC and GYIL, as successors to YBC, violated the non-compete clause by distributing competing batteries in the Philippines.

• Arbitral Tribunal Ruling: The tribunal ruled against Ramcar, finding it was not the real party-in-interest to sue for breach (only OYBC could). It also found that GYC/GYIL did not violate the JVA because OYBC had already ceased manufacturing.
• RTC Ruling: Ramcar petitioned the RTC to vacate the award. The RTC granted the petition, reversing the tribunal's findings and declaring that Ramcar *was* the real party-in-interest and that the tribunal wrongly decided an issue not submitted to it (OYBC's cessation of business).
• CA Ruling: The CA affirmed the RTC's decision to vacate and correct the arbitral award.

• Was the arbitration domestic or international in nature?
• Did the RTC and CA exceed their authority by reviewing the merits of the arbitral award?

The Supreme Court PARTLY GRANTED the petition, reversing the CA and RTC on most points.

• Arbitration was International: The Court ruled that the arbitration was international because the original parties (Ramcar and YBC) had their places of business in different states (Philippines and Japan). This single factor is sufficient under the law, regardless of other connections to the Philippines.
• Courts Cannot Review Merits: The RTC and CA committed a reversible error by reviewing the merits of the arbitral award. The issue of whether Ramcar was a real party-in-interest was a question of fact and law that the arbitral tribunal had the authority to decide. Courts cannot substitute their judgment for that of the tribunal, even if they believe the tribunal made an error.
• Valid Ground for Correction: The only part of the RTC/CA decision that was correct was setting aside the tribunal's finding on OYBC's cessation of business. This was a valid ground for judicial intervention because that specific issue was not included in the parties' agreed-upon Amended Terms of Reference (ATOR).

• International Arbitration: An arbitration is international if the parties, at the time of their agreement, have their places of business in different states. This is a primary determinant.
• Judicial Restraint in Arbitration: Courts cannot set aside an arbitral award merely because they disagree with the tribunal's findings of fact or conclusions of law. Judicial review is strictly limited to the grounds enumerated in the arbitration laws (e.g., R.A. 876, the Model Law).
• Scope of Submission: A valid ground to vacate an arbitral award is when the tribunal decides on matters beyond the scope of what the parties agreed to submit to arbitration (e.g., issues not listed in the Terms of Reference).