Pacific Micronesian Line v. Rosario
REITERATIONFacts
The Antecedents: Alfonsa Pelingon filed a claim for compensation for herself and her two minor children against Luzon Stevedoring Co., Inc. for the death of her husband, Luceno Pelingon. Luzon Stevedoring Co., Inc. refused the claim, stating it was not the employer. Procedural History: The Workmen's Compensation Commission (WCC) served notice of the claim on Pacific Far East Line, Inc., believing it to be an agent of petitioner Pacific Micronisian Line, Inc. (a foreign corporation). Pacific Far East Line, Inc. forwarded the notice to petitioner. Petitioner, through special appearance, moved to dismiss the claim, asserting the WCC lacked jurisdiction over it as a foreign corporation not doing business in the Philippines. The WCC referee denied the motion, holding that the failure of Pacific Micronisian Line, Inc. to contest Luzon Stevedoring Co., Inc.'s act of signing as its agent in employing the deceased conferred jurisdiction. The referee's order was reaffirmed by the Acting Commissioner, who emphasized the duty to uphold the rights of Filipino citizens against foreign corporations. Petitioner filed a petition for prohibition with the Supreme Court. The Petition: Petitioner seeks to restrain the WCC from exercising jurisdiction over it, arguing it is a foreign corporation not doing business in the Philippines and thus not amenable to service of process within the jurisdiction.
Issue(s)
Whether the Workmen's Compensation Commission has jurisdiction over the petitioner, a foreign corporation not doing business in the Philippines. Whether service of process made upon Pacific Far East Line, Inc., an alleged agent of the petitioner, is sufficient to confer jurisdiction upon the Workmen's Compensation Commission over the petitioner.
Ruling
The petition is granted. The Workmen's Compensation Commission has no jurisdiction over the petitioner. The proceedings are dismissed.
Ratio Decidendi
On the issue of jurisdiction over the petitioner: The Court held that for a foreign corporation to be amenable to the jurisdiction of Philippine courts, it must be 'doing business' in the Philippines. This requires continuity of conduct and an intention to establish a continuous business, not merely isolated or casual acts. Petitioner, a foreign corporation exclusively engaged in business between Guam and the Trust Territories of the Pacific Islands, had no property or office in the Philippines and was not licensed to do business therein. The act of securing the services of Luceno Pelingon through Luzon Stevedoring Co., Inc. was an isolated act, incidental and casual, and not indicative of a purpose to engage in business within the Philippines. Therefore, petitioner was not 'doing business' in the Philippines in contemplation of law. On the sufficiency of service of process: Section 14, Rule 7 of the Rules of Court requires that a foreign corporation be 'doing business in the Philippines' for service of process to be effective. The rule provides for service on a designated resident agent, a government official, or any officer or agent within the Philippines. However, this is contingent upon the foreign corporation being engaged in business within the jurisdiction. Since the Court found that petitioner was not doing business in the Philippines, service of process upon Pacific Far East Line, Inc., even if considered an agent for the isolated act of employment, could not confer jurisdiction upon the Workmen's Compensation Commission. The Court also dismissed the contention that the act of notifying the widow and providing aid was a business transaction, characterizing it as a pure act of humanity.
Main Doctrine
A foreign corporation not doing business in the Philippines is not amenable to the jurisdiction of Philippine courts, and service of process upon an agent who represented it in an isolated transaction does not confer jurisdiction.