R. Transport Corporation v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Floserida L. Castañeda filed a complaint for damages against R. Transport Corporation for breach of contract of carriage. The case was lodged with the Regional Trial Court of Makati, Metro Manila. 2. Procedural History: Summons was served on R. Transport Corporation at its Sucat Road, Parañaque address to its Operations Manager, Cesar Pasquin. The trial court declared the petitioner in default upon motion by the private respondent. Petitioner's motion to dismiss and to stop the ex parte reception of evidence, arguing improper service of summons, was denied. A subsequent motion for reconsideration, asserting that summons was served at the wrong location and not on an authorized officer, was also denied. Petitioner then filed a petition for certiorari with the Court of Appeals, which dismissed the petition, finding no grave abuse of discretion by the trial court. The appellate court denied petitioner's motion for reconsideration, leading to the present petition. 3. The Petition: This is a petition for review on certiorari under Rule 45 of the Revised Rules of Court. Petitioner argues that the trial court did not acquire jurisdiction over its person due to improper service of summons. Specifically, it contends that the summons was served on its Operations Manager at its bus terminal in Sucat, Parañaque, and not at its principal office in Makati, and that the person served was not an officer authorized to receive summons under Section 13, Rule 14 of the Revised Rules of Court.
Issue(s)
Whether the service of summons on the petitioner's Operations Manager at its bus terminal was valid and sufficient to vest the trial court with jurisdiction over the domestic corporation.
Ruling
The petition is DENIED. The Supreme Court affirmed the decision of the Court of Appeals, holding that the trial court acquired jurisdiction over the petitioner corporation.
Ratio Decidendi
On Issue 1: The Supreme Court held that the service of summons on the petitioner's Operations Manager was valid. Under Section 13, Rule 14 of the Rules of Court, service on a domestic corporation may be made on the president, manager, secretary, cashier, agent, or any of its directors. Following the ruling in Villa Rey Transit, Inc. v. Far East Motor Corporation, the Court emphasized that these rules are liberalized to include any representative so integrated with the corporation that they would likely understand the responsibility of receiving legal papers. The Court found that an Operations Manager is an officer who can be relied upon to appreciate the importance of the papers served, thus serving the purpose of the law. Furthermore, the petitioner failed to overcome the presumption of regularity in the performance of official duty by the process server, as provided in Rule 131, Section 3(m). The affidavit of the petitioner's president was deemed self-serving and insufficient to disprove the Officer's Return, which constitutes prima facie evidence of the facts stated therein. Finally, the Court distinguished this case from First Integrated Bonding & Insurance Co., Inc. v. Dizon, noting that an Operations Manager's duties generally pertain to the overall business of the corporation rather than just a specific branch, making them a valid recipient of service regardless of the location.
Main Doctrine
Service of summons on a corporation's Operations Manager at its bus terminal, who is an officer that may be relied upon to appreciate the importance of the papers served, is valid and confers jurisdiction over the corporation, even if not served at its principal office on one of the officers enumerated in Section 13, Rule 14 of the Revised Rules of Court.