St. Aviation Services v. Grand International Airways
REITERATIONFacts
The Antecedents: St. Aviation Services Co., Pte., Ltd. (petitioner), a Singapore-based corporation engaged in aircraft maintenance and repair, entered into agreements with Grand International Airways, Inc. (respondent), a domestic airline company, for the maintenance and modification of two aircraft. Petitioner completed the contracted works and delivered the aircraft. Subsequently, petitioner billed respondent for US$303,731.67 (S$452,560.18). Despite repeated demands, respondent failed to pay the outstanding amount. Procedural History: Petitioner filed an action for the sum owed against respondent before the High Court of the Republic of Singapore, which rendered a judgment by default against respondent after service of summons. Petitioner then filed a Petition for Enforcement of Judgment with the Regional Trial Court (RTC), Branch 117, Pasay City. Respondent moved to dismiss the petition, arguing that the Singapore High Court lacked jurisdiction over its person and that the foreign judgment was void due to a violation of due process. The RTC denied the motion to dismiss. Respondent filed a Petition for Certiorari with the Court of Appeals, which granted the petition and set aside the RTC's orders, finding that the extraterritorial service of summons was defective and that the Singapore court had not acquired jurisdiction. Petitioner's motion for reconsideration was denied. The Petition: Petitioner seeks review of the Court of Appeals' decision and resolution through a Petition for Review on Certiorari under Rule 45 of the Rules of Court. The core issues presented are whether the Singapore High Court acquired jurisdiction over the respondent through the service of summons in the Philippines and whether the default judgment rendered by the Singapore High Court is enforceable in the Philippines. Petitioner contends that the service of summons was effected in accordance with Philippine law, thereby conferring jurisdiction upon the Singapore court, and that the foreign judgment is valid and enforceable.
Issue(s)
Whether the Singapore High Court acquired jurisdiction over the person of respondent by the service of summons upon its office in the Philippines. Whether the judgment by default in Suit No. 2101 by the Singapore High Court is enforceable in the Philippines.
Ruling
The Supreme Court granted the petition, set aside the decision and resolution of the Court of Appeals, and directed the RTC to hear the case with dispatch.
Ratio Decidendi
On whether the Singapore High Court acquired jurisdiction over the person of respondent by the service of summons upon its office in the Philippines: The Court held that jurisdiction over the person of a defendant in an action in personam is acquired through personal or substituted service of summons. In this case, the Singapore High Court granted leave to serve the Writ of Summons extraterritorially upon respondent in the Philippines, specifically by a method of service authorized by Philippine law for the service of any originating process issued by a Philippine court. The Sheriff's Return indicated that the summons was received by respondent's secretary at its office in Pasay City. The Court found this service to be in accordance with Philippine rules on service of process, thus conferring jurisdiction upon the Singapore High Court over the person of the respondent. The fact that respondent completely ignored the summons led to its declaration in default, which was a consequence of its failure to respond despite proper service. On whether the judgment by default in Suit No. 2101 by the Singapore High Court is enforceable in the Philippines: The Court reiterated the general rule that foreign judgments are given effect in the Philippines under the principle of comity, provided certain conditions are met. Section 48, Rule 39 of the 1997 Rules of Civil Procedure states that a foreign judgment against a person is presumptive evidence of a right between the parties and may be repelled by evidence of want of jurisdiction, want of notice, collusion, fraud, or clear mistake of law or fact. In this case, the Court found that the Singapore High Court had acquired jurisdiction over respondent through valid service of summons. Therefore, the judgment by default rendered by that court was considered valid and enforceable in the Philippines, as there was no showing of want of jurisdiction, want of notice, collusion, fraud, or clear mistake of law or fact that would warrant repelling its validity. The Court emphasized that the party attacking a foreign judgment bears the burden of overcoming the presumption of its validity.
Main Doctrine
A foreign judgment rendered by a court of competent jurisdiction is enforceable in the Philippines under the principle of comity, provided it is not contrary to public policy and the party against whom it is enforced was given due notice and an opportunity to be heard. Jurisdiction over the person in an action in personam is acquired through personal or substituted service of summons as provided by the Rules of Court.