Manguiat v. Court of Appeals
REITERATIONFacts
The Antecedents: The petitioners, heirs of various individuals, claim to be the equitable owners of Lot 1993-I, also known as the "Calamba Estate." They assert their rights stem from a Sales Certificate awarded to their predecessors-in-interest on November 13, 1914, under the Friar Land Act. They filed a complaint seeking to quiet title and cancel the Torrens titles issued to respondents J.A. Development Corporation (JDC), Bureau of Telecommunications (BUTEL), Juan dela Cruz, and Pedro dela Cruz, alleging these titles were improperly obtained. Procedural History: The petitioners filed their complaint with the Regional Trial Court (RTC) of Tagaytay City. Summons was served on JDC and BUTEL. JDC moved to dismiss, which the RTC denied. The RTC later declared BUTEL in default and issued a partial decision on February 18, 2000, declaring the petitioners as equitable owners and ordering the cancellation of BUTEL's title. JDC moved to set aside this partial decision, arguing it prejudged the entire case, but the RTC denied this motion and ordered the issuance of a writ of execution. JDC then filed a petition for certiorari and prohibition with the Court of Appeals (CA) seeking to annul the partial decision, the denial of its motion, and the writ of execution. Separately, the Republic of the Philippines, through the Solicitor General, filed a petition for Annulment of Judgment with the CA, seeking to nullify the partial decision due to alleged lack of jurisdiction stemming from improper service of summons on BUTEL. The CA, in two separate divisions, granted both petitions, setting aside the RTC's partial decision and subsequent orders. The Petition: The petitioners filed two separate petitions for review on certiorari with the Supreme Court. In G.R. No. 150768, they assail the CA's decision in CA-G.R. SP No. 60770, arguing that the RTC's partial decision was proper as the causes of action against the defendants were distinct and severable. In G.R. No. 160176, they challenge the CA's decision in CA-G.R. SP No. 61703, asserting that summons was validly served on the Republic of the Philippines and that the failure to notify the Solicitor General was BUTEL's negligence. The core issues before the Supreme Court are whether jurisdiction was validly acquired over BUTEL and whether the partial default judgment was proper.
Issue(s)
Whether the Regional Trial Court validly acquired jurisdiction over the Bureau of Telecommunications (BUTEL) through service of summons on an ordinary employee instead of the Solicitor General. Whether the Regional Trial Court committed grave abuse of discretion in rendering a partial decision against a defaulted defendant when a common cause of action was stated against multiple defendants.
Ruling
The Supreme Court denied the petitions for lack of merit. It affirmed the decisions of the Court of Appeals in both CA-G.R. SP No. 60770 and CA-G.R. SP No. 61703, thereby annulling and setting aside the partial decision of the Regional Trial Court dated February 18, 2000, its order dated July 17, 2000, and the writ of execution dated August 8, 2000.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that jurisdiction over the Bureau of Telecommunications (BUTEL) was never acquired. Under Rule 14, Section 13 of the 1997 Rules of Civil Procedure, service of summons upon the Republic of the Philippines must be effected on the Solicitor General. Since BUTEL is an agency attached to the Department of Transportation and Communications (DOTC) and is indisputably part of the Republic, summons should have been served on the Solicitor General as its statutory counsel. The sheriff's return clearly indicated that the summons was received by a certain Cholito Anitola, an ordinary employee, which does not satisfy the legal requirement. Citing Laus v. Court of Appeals, the Court noted that the presumption of regularity in the performance of official duty does not apply when the sheriff's return is patently defective on its face. Consequently, all proceedings against BUTEL were null and void for lack of jurisdiction. On Issue 2: The Court held that the trial court committed grave abuse of discretion by rendering a partial decision. Rule 9, Section 3(c) of the 1997 Rules of Civil Procedure explicitly provides that when a pleading asserts a common cause of action against several defending parties, and some fail to answer, the court shall try the case against all upon the answers filed and render judgment upon the evidence presented. This 'common cause of action' rule ensures that the answer of the non-defaulting defendant (JDC) inures to the benefit of the defaulted defendant (BUTEL), as they share a common fate in the action. By rendering a partial decision based on evidence presented ex parte against BUTEL, the trial court effectively pre-judged the entire case and the merits of JDC's own claim of ownership. This procedure violates the due process rights of the defaulted defendant and the procedural rights of the appearing defendant to have the case heard as a whole.
Main Doctrine
The Court of Appeals correctly set aside the partial decision of the trial court due to grave abuse of discretion, as the trial court's declaration of default against one defendant and its subsequent ex parte judgment constituted a prejudgment of the entire case. Furthermore, the trial court acquired no jurisdiction over the Bureau of Telecommunications (BUTEL) due to invalid service of summons, as it was served on an ordinary employee and not on the Solicitor General as required by law.