Guanzon v. Arradaza
REITERATIONFacts
The Antecedents: Respondent Andrew B. Arradaza filed an amended complaint for damages against Francisca Maidin and Erlinda Lebita, owners and operators of a jeepney, and Reynaldo Lebita, the driver. He also sued Erlinda Guanzon, the registered owner of a dump truck, and Ruel Escarilla, its driver. Arradaza alleged that while he was a passenger in the jeepney, a collision occurred between the jeepney and the dump truck due to the negligence of both drivers. As a result, Arradaza sustained injuries, incurred medical expenses, and suffered loss of earnings. He claimed that the jeepney drivers failed to exercise due diligence, and Guanzon, as the dump truck owner, failed to exercise due diligence in hiring her driver. Procedural History: The Metropolitan Trial Court (MeTC) of Manila declared Guanzon in default for failing to file an answer. Guanzon's subsequent motion to dismiss, based on allegedly defective service of summons, was denied. The MeTC rendered a judgment in favor of Arradaza, ordering Maidin, Reynaldo Lebita, and Guanzon to pay damages jointly and severally. Guanzon appealed to the Regional Trial Court (RTC), which affirmed the MeTC's decision. Guanzon then filed a Petition for Review with the Court of Appeals, solely challenging the validity of the service of summons. The Court of Appeals denied the petition, upholding the lower courts' rulings. The Petition: Erlinda Guanzon filed a Petition for Review on Certiorari with the Supreme Court, raising the sole issue of whether the Court of Appeals erred in not giving due course to her petition and in denying it, despite her assertion that the sheriff's return clearly indicated defective substituted service of summons, rendering the proceedings null and void. Guanzon argued that the substituted service on her was defective and did not confer jurisdiction over her person. The Supreme Court, however, found that the service of summons, initially attempted personally and subsequently by substituted service, met the requirements of the Rules of Court and due process, and therefore denied the petition.
Issue(s)
Whether the MeTC acquired jurisdiction over the person of petitioner Erlinda Guanzon by reason of the substituted service of summons. Whether the substituted service of summons on petitioner Erlinda Guanzon was valid.
Ruling
The Supreme Court denied the petition for lack of merit and affirmed the decision of the Court of Appeals, which upheld the decisions of the RTC and MeTC. The Court ruled that there was proper service of summons on petitioner Guanzon, and the MeTC properly acquired jurisdiction over her person.
Ratio Decidendi
On the issue of jurisdiction over the person of petitioner Erlinda Guanzon: The Court reiterated the available remedies for a party declared in default, including filing a motion to set aside the order of default, a motion for new trial, a petition for relief, or an appeal from the judgment. It noted that petitioner Guanzon, instead of availing herself of these remedies, filed a Motion to Dismiss almost two years after being declared in default, predicated on defective service of summons. The Court found this procedural approach to be improper. Furthermore, the Court examined the service of summons. Initial attempts at personal service on Guanzon at her registered address failed as she was unknown there. Subsequently, based on information from the Securities and Exchange Commission, summons was attempted via substituted service at her office or regular place of business. The sheriff's return indicated that service was made on Susan Ador, who was of suitable age and employed within the premises where Guanzon also worked. The Court found that this substituted service met the requirements of the Rules of Court and the due process clause. The sheriff's return, being prima facie evidence of the facts stated therein, was not overcome by clear and convincing evidence from the petitioner. Therefore, the MeTC properly acquired jurisdiction over Guanzon's person. On the validity of the substituted service of summons: The Court emphasized that summons is the writ by which a defendant is notified of an action, and its service is the means by which a court acquires jurisdiction over the person. While personal service is the general rule, substituted service is permissible when personal service cannot be effected within a reasonable time. The Rules of Court provide for two modes of substituted service: (a) leaving copies at the defendant's residence with a person of suitable age and discretion residing therein, or (b) leaving copies at the defendant's office or regular place of business with a competent person in charge thereof. In this case, the service was effected at Guanzon's regular place of business with Susan Ador, who appeared to be in charge. The Court held that it is not necessary for the person in charge to be specifically authorized to receive summons; it is sufficient if they appear to be in charge. The constitutional requirement of due process is satisfied if the service is reasonably expected to give the defendant notice of the action. The Court found that the substituted service in this case met this standard, as it was effected after attempts at personal service failed and was made at Guanzon's place of business with a person of suitable age and discretion who was working there. The sheriff's return, which detailed these actions, was given credence.
Main Doctrine
Substituted service of summons, when properly effected in accordance with the Rules of Court and the due process clause, is valid and confers jurisdiction over the person of the defendant. A sheriff's return is prima facie evidence of the facts stated therein, and to overcome this presumption, clear and convincing evidence is required.