Keister v. Navarro
REITERATIONFacts
The Antecedents: Batjak, Inc., a Philippine corporation, was the registered owner of an automobile. James A. Keister, its President-General Manager, sold the automobile to Juan T. Chuidian, who then reconveyed it to Keister. Batjak, Inc. claimed these transactions were without its authority. Batjak, Inc. took possession of the automobile, but it later disappeared and was subsequently recovered by the Land Transportation Commission, which turned it over to the Philippine Constabulary (CIS). Batjak, Inc. filed a complaint for annulment of sale with attachment against the CIS and Keister, seeking to annul the sale, attach the automobile, cancel Keister's registration, and recover damages. The complaint stated Keister could be served at c/o Chuidian Law Office and alleged he had secretly left the Philippines. Procedural History: Summons was served at the Chuidian Law Office, received by an office clerk. Keister, through counsel, filed a special appearance and motion to dismiss, arguing improper service of summons and lack of jurisdiction. The respondent Judge denied the motion, stating the address in the complaint prevailed and service was made there. A motion for reconsideration was also denied. The Petition: Keister filed a special civil action for prohibition to prevent the respondent Judge from enforcing his orders and proceeding with the trial, asserting the court had not acquired jurisdiction over his person.
Issue(s)
Whether the respondent Court acquired jurisdiction over the person of the petitioner. Whether the service of summons upon the petitioner was valid.
Ruling
The petition for prohibition is GRANTED, and the writ of preliminary injunction issued is made permanent. The Orders of January 12, 1968, and March 28, 1968, are declared null and void.
Ratio Decidendi
On Issue 1: The Court held that jurisdiction over the person of the defendant is acquired through valid service of summons. Without such service, or a valid waiver thereof, any trial and judgment are null and void. The purpose of summons is not only to give the court jurisdiction but also to afford the defendant an opportunity to be heard. The constitutional requirement of due process mandates that service must be such as to reasonably expect to give notice to the party of the claim against him. In this case, the service of summons was fatally defective, thus the court a quo failed to acquire jurisdiction over the person of petitioner James A. Keister. On Issue 2: The Court reiterated that summons must be served personally to the defendant. Substituted service is permissible only when personal service cannot be effected within a reasonable time, and strict adherence to statutory requirements is necessary. Section 8 of Rule 14 of the Revised Rules of Court provides for substituted service by leaving copies at the defendant's dwelling house or residence with a person of suitable age and discretion residing therein, or at his office or regular place of business with a competent person in charge. The residence of Keister was at 11 Narra Road, Forbes Park, Makati, Rizal, and his former place of business was at the Batjak Corporation office. Service was not effected at either of these locations in the manner prescribed by law. The fact that Keister had allegedly left the Philippines secretly and surreptitiously does not justify service at a place that is neither his residence nor his regular place of business. Therefore, the service of summons was invalid.
Main Doctrine
Service of summons upon a defendant must be made personally, or by substituted service strictly in accordance with the rules, otherwise, the court fails to acquire jurisdiction over the person of the defendant, rendering subsequent orders and judgments void.