Herrera-Felix v. Court of Appeals
REITERATIONFacts
The Antecedents: Respondent St. Joseph Resource Development, Inc. filed a complaint for sum of money against Spouses Restituto and Ofelia Felix, alleging an outstanding obligation of P1,132,065.50 for fish purchases made between November 16, 1992, and December 14, 1992. The respondent also sought a writ of preliminary attachment against the spouses' properties. Procedural History: The trial court granted the writ of preliminary attachment and subsequently, summons and the complaint were served on the Felix Spouses. Despite a motion for extension to file an answer, they failed to do so, leading to their declaration of default. The trial court rendered a decision in favor of the respondent, ordering the spouses to pay the outstanding obligation and attorney's fees. This decision became final and executory after the spouses failed to appeal. Consequently, personal properties of the spouses were levied and sold at public auction. The Petition: Petitioner Ofelia Herrera-Felix, through her sister, filed a petition with the Court of Appeals under Rule 47 of the Rules of Court, seeking to annul the trial court's judgment, writ of execution, and the sale of her properties. She argued that the substituted service of summons was invalid and that her husband had already died prior to the proceedings. The Court of Appeals dismissed the petition, finding that the trial court had validly acquired jurisdiction and that there were no grounds for annulment. The petitioner now seeks review by this Court, reiterating her arguments regarding lack of jurisdiction and denial of due process.
Issue(s)
Whether the RTC acquired jurisdiction over the person of petitioner Ofelia Herrera-Felix; and whether the service of summons through substituted service was valid. Whether the filing of a motion for extension of time to file an answer constituted a voluntary submission to the jurisdiction of the court. Whether the petitioner was properly served with a copy of the RTC's decision. Whether the petitioner was deprived of her right to due process.
Ruling
The petition is denied due course, and the assailed decision of the Court of Appeals is affirmed. The Supreme Court ruled that the RTC validly acquired jurisdiction over the person of the petitioner, and there were no grounds to annul the judgment.
Ratio Decidendi
On the RTC's acquisition of jurisdiction and validity of substituted service: The Court held that jurisdiction over the person is acquired through personal service, substituted service, extra-territorial service, or voluntary appearance. In this case, the petitioner, through her counsel, filed a motion for an extension of time to file an answer, admitting service of the complaint and summons. This act constituted a judicial admission and a voluntary submission to the jurisdiction of the RTC. The Court reiterated the principle that an appearance, without an explicit objection to the court's jurisdiction, is a waiver of the necessity of formal notice and an assent to the court's jurisdiction over the person. The filing of a motion for any purpose other than to object to jurisdiction submits the party to the court's jurisdiction. On the filing of a motion for extension of time: The Court held that filing a motion for extension of time to file an answer constitutes a voluntary submission to the jurisdiction of the court. On the service of the decision: The Court found the petitioner's claim of not being served a copy of the decision to be without merit. The records showed that a copy was sent by registered mail to the petitioner and another copy was served on her counsel, Atty. Celestino C. Juan, who received it. Service of pleadings and resolutions on counsel is binding on the client. On due process: The Court emphasized that due process requires a reasonable opportunity to be heard, and a party who fails to avail of this opportunity through their own fault cannot claim denial of due process. The petitioner had the opportunity to answer and defend herself but failed to do so.
Main Doctrine
A party who files a motion for extension of time to file an answer, admitting service of the complaint and summons, submits to the jurisdiction of the court. Such appearance, unless specifically objecting to the court's jurisdiction, constitutes a waiver of the necessity of formal notice and an assent to the court's jurisdiction over the person.