Weena Express v. Rapacon
REITERATIONFacts
The Antecedents: A vehicular accident occurred on March 14, 1995, along the National Highway in Bansalan, Davao del Sur, involving a cargo truck owned by Godofredo Rapacon and driven by Rene Gucon, and a bus owned and driven by Weena Express, Inc. (petitioner) and Sofonias Datulayta, respectively. The accident resulted in the death of a bystander, injuries to bus passengers, and damage to the cargo truck. Procedural History: Respondents demanded damages from petitioner, which were unheeded. Respondents filed a Complaint for Damages against petitioner and Datulayta. Summons was served on petitioner through its claim employee, Rolando Devera, who claimed authority to receive it. Petitioner failed to file an answer, leading to its declaration in default by the Regional Trial Court (RTC). Petitioner's motion to lift the order of default and subsequent motion for reconsideration were denied. The RTC rendered a decision ex-parte in favor of respondents. The Petition: Petitioner and Datulayta appealed to the Court of Appeals (CA), arguing improper service of summons. The CA dismissed the complaint against Datulayta for lack of jurisdiction but affirmed the RTC's jurisdiction over petitioner, modifying the RTC decision by declaring it void as to Datulayta and deleting compensation for loss of income. Petitioner's motion for reconsideration was denied. Petitioner filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's ruling on jurisdiction over its person due to alleged invalid service of summons.
Issue(s)
Whether the trial court acquired jurisdiction over the person of the petitioner corporation despite the service of summons upon its claim employee. Whether a claim employee of a private domestic corporation can be considered an "agent" for the purpose of valid service of summons under the Rules of Court.
Ruling
The petition is DENIED. The Court of Appeals did not commit reversible error in holding that a summons was properly served on petitioner through its agent Devera, and that such service of summons effectively placed petitioner under the jurisdiction of the trial court.
Ratio Decidendi
On Issue 1: The Court affirmed the CA's ruling that the trial court acquired jurisdiction over the petitioner. The CA correctly held that service of summons on Rolando Devera, a claim employee of petitioner, was proper. Devera's role in following up cases filed by and against the corporation, as admitted by petitioner in its motion to lift the order of default, indicated that he was integrated with the corporation's operations concerning legal matters. The Sheriff's Return also stated that Devera claimed authority to receive summons. This evidence, coupled with Devera's admitted duties, led the Court to conclude that he was an agent within the contemplation of the Rules of Court. The Court found petitioner's denial of Devera's agency unconvincing against the presented evidence. Therefore, the service of summons upon Devera was binding on the corporation, establishing jurisdiction. On Issue 2: The Court reiterated that under Section 13, Rule 14 of the (1964) Rules of Court, service of summons on a private domestic corporation may be made on its president, manager, secretary, cashier, agent, or any of its directors. The Court, citing Villa Rey Transit, Inc. v. Far East Motor Corporation, defined an "agent" in this context as a representative so integrated with the corporation that it is supposable they will realize their responsibilities and know what to do with legal papers. Devera's admitted duty to follow up cases and his claim of authority to receive summons demonstrated this integration. His position was not merely that of a rank-and-file employee but one performing vital functions that would reasonably lead him to discern the importance of legal documents and transmit them to the corporation. Thus, Devera qualified as an agent for service of process.
Main Doctrine
Service of summons upon a claim employee of a private domestic corporation, whose primary duty involves following up cases filed by and against the corporation, is considered valid service upon an agent, thereby conferring jurisdiction upon the court over the corporation.