Delta Motor Sales Corp. v. Mangosing
REITERATIONFacts
The Antecedents: Jose Luis Pamintuan sued Delta Motor Sales Corporation (Delta Motor) for damages totaling P58,000, alleging breach of warranty on a Toyota car purchased from Delta Motor. Pamintuan claimed Delta Motor failed to properly repair defects in the vehicle, specifically leaks from the windshield, doors, and windows, despite its warranty obligations. Procedural History: Summons was served on Delta Motor on April 19, 1975, and the company failed to file an answer within the reglementary period. Consequently, Pamintuan filed a motion to declare Delta Motor in default, which was granted by the Court of First Instance of Manila on June 3, 1975. A default judgment was rendered on June 16, 1975, ordering Delta Motor to pay P45,000 in damages. Delta Motor's subsequent motion to lift the default order, set aside the judgment, and for a new trial was denied on July 29, 1975. A motion for reconsideration was also denied on August 25, 1975. Delta Motor filed a notice of appeal and record on appeal on September 5, 1975. However, the trial court refused to give due course to the appeal and granted Pamintuan's motion for execution in an order dated October 13, 1975. This petition for certiorari was filed on October 20, 1975. The Petition: Delta Motor seeks to annul the orders of the Court of First Instance of Manila denying its motions to set aside the default order and judgment, and granting the motion for execution. The core of Delta Motor's argument is that the summons was improperly served on Dionisia G. Miranda, an employee in the personnel department and not an officer authorized to receive such service under Section 13 of Rule 14 of the Revised Rules of Court. Delta Motor contends that this improper service meant the court never acquired jurisdiction over its person, rendering the default order, judgment, and subsequent execution void. The petition argues that strict compliance with the rules for service of process on a corporation is necessary to confer jurisdiction.
Issue(s)
Whether the Court of First Instance of Manila acquired jurisdiction over Delta Motor Sales Corporation due to the manner of service of summons. Whether the order of default, the judgment by default, and the order granting execution in Civil Case No. 97373 are void.
Ruling
The Court set aside the order of default, judgment by default, and all other proceedings in Civil Case No. 97373. The lower court was directed to admit the answer of Delta Motor. Respondent Pamintuan was allowed to file his answer in Civil Case No. 21303, and the record of that case was ordered transferred to the Court of First Instance of Manila. The parties were encouraged to reach an amicable settlement.
Ratio Decidendi
On the issue of jurisdiction and proper service of summons: The Court held that the Manila court did not acquire jurisdiction over Delta Motor because the service of summons on Dionisia G. Miranda was insufficient. Section 13 of Rule 14 of the Revised Rules of Court explicitly enumerates the persons authorized to receive summons for a private domestic corporation, namely, the president, manager, secretary, cashier, agent, or any of its directors. Dionisia G. Miranda, being merely a secretary to an employee in the personnel department, was not among those authorized. The purpose of the rule is to ensure that the corporation receives prompt and proper notice of legal actions against it, and this is achieved by serving designated officers who are integrated with the corporation and would know what to do with legal papers. The rule on service of summons on corporations is strict, and a particular mode indicated by statute must be followed. The liberal construction rule cannot be invoked to substitute for plain legal requirements regarding the manner of service. Therefore, the service on Miranda did not bind Delta Motor, rendering the subsequent order of default and judgment by default void. The Court cited numerous cases emphasizing the strict compliance required for service of process on corporations to confer jurisdiction. On the validity of the default judgment and execution: Since the Court found that the lower court never acquired jurisdiction over Delta Motor due to improper service of summons, the order of default, the judgment by default, and the subsequent order granting execution were all declared void and consequently set aside. The Court reiterated the principle that courts acquire jurisdiction over a party defendant by virtue of the service of summons in the manner required by law, and without such service or a voluntary general appearance, the court has no jurisdiction to pronounce a judgment. The sheriff's levy upon Delta Motor's properties to satisfy the void judgment was also nullified.
Main Doctrine
Service of summons on a private domestic corporation must strictly comply with Section 13 of Rule 14 of the Revised Rules of Court, which enumerates the specific officers or agents on whom service may be made. Service on any other person, even if an employee, does not confer jurisdiction over the corporation, rendering subsequent proceedings, including default judgments and executions, void.