Republic v. Domingo
REITERATIONFacts
1. The Antecedents: Alberto A. Domingo filed a complaint for specific performance with damages against the Department of Public Works and Highways (DPWH), Region III, alleging unpaid rentals for construction equipment leased to the DPWH from April to September 1992 for emergency projects related to Mt. Pinatubo. Domingo claimed the outstanding balance was ₱6,320,163.05, plus damages and attorney's fees, asserting that despite repeated demands, the DPWH Region III failed to pay. 2. Procedural History: The Regional Trial Court (RTC) of Malolos, Bulacan, declared the DPWH Region III in default after it failed to file a responsive pleading. Following an ex parte presentation of evidence, the RTC rendered a decision on February 18, 2003, ordering the DPWH Region III to pay Domingo the principal amount, interest, and attorney's fees. Domingo moved for execution, which the RTC granted. Subsequently, the Republic of the Philippines, represented by the Office of the Solicitor General (OSG), filed a Petition for Annulment of Judgment with the Court of Appeals (CA), arguing lack of jurisdiction due to improper service of summons. The CA dismissed the petition, and its resolution was later denied. The Republic then filed a petition for review on certiorari with the Supreme Court. 3. The Petition: The Republic of the Philippines, through a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeks to reverse the CA's decision. The Republic argues that the RTC never acquired jurisdiction over it because summons was not served on the Solicitor General, as required by Section 13, Rule 14 of the Rules of Court, when the defendant is the Republic of the Philippines. The Republic contends that the DPWH and its regional office are merely agents of the Republic, which is the real party in interest, and that the failure to serve summons on the OSG renders the RTC proceedings and decision void. The Republic also argues that the State is not bound by the errors of its agents and that Domingo could only recover on a quantum meruit basis.
Issue(s)
Whether the Court of Appeals correctly dismissed the Petition for Annulment of Judgment filed by the Republic. Whether the Regional Trial Court acquired jurisdiction over the Republic of the Philippines in Civil Case No. 333-M-2002, and whether the service of summons upon DPWH Region III was sufficient to acquire jurisdiction over the Republic of the Philippines.
Ruling
The Supreme Court granted the petition, reversed the Court of Appeals' decision, and annulled and set aside the Regional Trial Court's decision, without prejudice to the refiling of the original action in the proper court.
Ratio Decidendi
The Court held that the Court of Appeals failed to apply or even consider the crucial provision of the Rules of Court regarding service of summons. The Court reiterated that jurisdiction over the person of the defendant is acquired through the service of summons or voluntary appearance. The Court disagreed with Domingo's argument that the Republic is estopped from raising the issue of jurisdiction due to the OSG's appearance in other cases, as those cases involved different transactions and there was no indication that the OSG had notice of the present case. The duty to implead all necessary or indispensable parties and to effect proper service of summons rests upon the plaintiff, and Domingo failed to discharge this burden. On the issue of jurisdiction and service of summons: The Court held that the Republic of the Philippines was not validly served with summons in Civil Case No. 333-M-2002. Section 13, Rule 14 of the Rules of Court explicitly states that when the defendant is the Republic of the Philippines, service of summons may be effected on the Solicitor General. The DPWH and its regional offices are merely agents of the Republic, which is the real party in interest. Therefore, the summons should have been served on the OSG, not solely on DPWH Region III. In this case, there was no valid service of summons upon the Republic, and thus the RTC failed to acquire jurisdiction over its person. Consequently, all proceedings had before the trial court and its Decision dated February 18, 2003, are declared void.
Main Doctrine
Service of summons upon the Republic of the Philippines must be made on the Solicitor General as mandated by Section 13, Rule 14 of the Rules of Court. Failure to comply with this requirement results in the RTC's lack of jurisdiction over the person of the Republic, rendering all subsequent proceedings and judgments void.