Cordova v. Provincial Sheriff of Iloilo
REITERATIONFacts
The Antecedents: Roseminda Vda. de Dejando, for herself and her minor son, filed a death compensation claim against Antero Edrosolano (alleged operator) and Carlos Cordova (petitioner, alleged owner) for the death of Demetrio Dejando, a taxi driver, who was shot while driving an Ame taxi on February 16, 1967. The claim was filed with the Workmen's Compensation Unit (WCU), Regional Office No. VII, Iloilo City, docketed as WCU Case No. 12756. Procedural History: The WCU issued summons on April 11, 1967, directed to "Mr. Antero Edrosolano and/or Carlos Cordova c/o Atty. Cirilo Y. Ganzon, Isnart Street, Iloilo City." Petitioner Carlos Cordova claims he was never served with this summons and was unaware of the case until October 1968, when he received a writ of execution. He filed a special appearance and motion for reconsideration with the WCU, questioning its jurisdiction over him due to lack of summons. This motion was not acted upon. Meanwhile, the Provincial Sheriff of Iloilo levied upon petitioner's properties for public auction. Petitioner filed a civil case for injunction with the Court of First Instance of Iloilo, which was dismissed for lack of jurisdiction to enjoin the WCU's writ. Subsequently, petitioner filed the present petition for certiorari with preliminary injunction with the Supreme Court. The Petition: Petitioner Carlos Cordova seeks to set aside the decision of the WCU in WCU Case No. 12756, alleging grave abuse of discretion amounting to lack of jurisdiction. The lone principal issue raised is the WCU's failure to acquire jurisdiction over his person due to the non-service of summons. Petitioner contends that the summons was not served on him, that the address used was that of Atty. Ganzon, whom he never authorized to represent him, and that his actual address was known and not used. He asserts that he was never the owner or operator of the Ame taxi and thus not the employer of the deceased.
Issue(s)
Whether the Workmen's Compensation Unit acquired jurisdiction over the person of petitioner Carlos Cordova. Whether the decision rendered by the Workmen's Compensation Unit against petitioner is valid.
Ruling
The Supreme Court ruled in favor of the petitioner. It held that the Workmen's Compensation Unit never acquired jurisdiction over the person of petitioner Carlos Cordova for failure to serve him with summons. Consequently, the decision of the WCU in WCU Case No. 12756, insofar as it affects petitioner, is set aside, the writ of execution issued against him is nullified, and the restraining order issued by the Supreme Court is made permanent.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Workmen's Compensation Unit (WCU) never acquired jurisdiction over the person of petitioner Carlos Cordova. The evidence clearly showed that the summons issued on April 11, 1967, was directed to "Mr. Antero Edrosolano and/or Carlos Cordova c/o Atty. Cirilo Y. Ganzon, Isnart Street, Iloilo City." This address was not petitioner's known address, which was "La Granja La Paz, Iloilo City." Petitioner credibly denied under oath that Atty. Ganzon was authorized to represent him in WCU Case No. 12756. Furthermore, petitioner never appeared in the original hearing nor during the rehearing granted after a motion for reconsideration, which supports his claim of ignorance of the case. The Court found no evidence that petitioner received the summons, as it was addressed to an attorney and not to petitioner's actual residence. On Issue 2: As a consequence of the lack of jurisdiction over the person of the petitioner, the decision rendered by the WCU in WCU Case No. 12756, in so far as it affects petitioner Carlos Cordova, is void. A judgment rendered by a court or quasi-judicial body without acquiring jurisdiction over the person of a party is a nullity and cannot be enforced. The Court emphasized that the right to due process, which includes proper notice and hearing, was violated. Therefore, the writ of execution issued to enforce this void decision against petitioner's properties was also nullified, and the restraining order issued by the Supreme Court was made permanent.
Main Doctrine
The Workmen's Compensation Unit, Regional Office No. VII, Department of Labor, failed to acquire jurisdiction over the person of petitioner Carlos Cordova due to the improper service of summons. The summons was directed to an attorney's address and not to petitioner's known address, and petitioner credibly denied authorizing said attorney to represent him. Consequently, the decision rendered by the Unit against petitioner, as well as the writ of execution issued, are void and cannot be enforced against him.