Villarama v. Guno
REITERATIONFacts
The Antecedents: Sps. Reyes sold a house and lot to Sps. Guno, evidenced by a deed of absolute sale and promissory notes. Sps. Reyes later executed a Trust Agreement with Prudential Bank, naming their children as beneficiaries, and subsequently amended it to name petitioner Ramon Villarama as an irrevocable beneficiary. Sps. Guno obtained loans from Prudential Bank, mortgaged the property, defaulted, and Prudential Bank foreclosed the mortgage, consolidated ownership, and placed Villarama in possession. Sps. Guno filed a complaint for annulment of foreclosure sale and title against Prudential Bank, which was affirmed by the RTC, CA, and Supreme Court. Procedural History: Villarama filed a Complaint for Rescission of Promissory Notes, Deed of Sale of Real Property and Cancellation of Title with Damages against Sps. Guno. Alias summons was served via substituted service on Carmelita Guno at her office, with a notation that it was received for her only. Summons to Crisantomas Guno was returned unserved as he did not reside or hold office there. Subsequently, substituted service was effected on Crisantomas Guno at his sister's residence. Carmelita filed an Answer, while Crisantomas was declared in default. The RTC rendered judgment rescinding the promissory notes and deed of sale, ordering cancellation of title, and awarding damages and attorney's fees. Crisantomas filed a Special Appearance with Motion to Vacate Judgment, claiming improper service of summons. The RTC denied the motion, ruling that service on Carmelita was binding on Crisantomas. The Court of Appeals reversed the RTC's order, finding no valid service of summons on Crisantomas. The Petition: Villarama filed a Petition for Review on Certiorari, assailing the CA's decision and resolution, and positing the sole issue of whether summons was validly served on Crisantomas.
Issue(s)
Whether the alias summons served upon Carmelita Guno was binding upon Crisantomas D. Guno. Whether there was valid service of summons on Crisantomas D. Guno in Civil Case No. Q-97-31700.
Ruling
The Supreme Court granted the petition, reversed the Court of Appeals' decision and resolution, and denied Crisantomas Guno's Motion to Vacate Judgment. The Court ruled that the alias summons served upon Carmelita Guno was binding upon Crisantomas D. Guno.
Ratio Decidendi
On the issue of whether the alias summons served upon Carmelita Guno was binding upon Crisantomas D. Guno: The Court found merit in the petition and ruled that the RTC was correct in holding that the alias summons served upon Carmelita was binding upon Crisantomas. The Court emphasized that jurisdiction over a defendant is founded on a valid service of summons, which is essential for due process. In this case, the alias summons was served on both Crisantomas and Carmelita at Carmelita's office, and she participated in the proceedings. Crisantomas' denial of receipt, unsupported by additional evidence, was insufficient to overcome the presumption of validity. The Court noted that Crisantomas did not substantiate his claims of separation in fact or annulment of marriage at the time of service, and that Carmelita's initial pleadings indicated they shared the same address for service. The Court reiterated that bare allegations unsubstantiated by evidence are not equivalent to proof, citing GSIS v. Prudential Guarantee and Assurance, Inc. The Court also pointed out that Carmelita's participation in the proceedings, where she fully litigated their interests, demonstrated that the core of due process was not transgressed. The Court further cited Montefalcon, et al. vs. Vasquez, stating that a plaintiff is only required to know the defendant's residence, office, or regular business place and is not duty-bound to ensure actual delivery of the summons to the defendant. On the issue of whether there was valid service of summons on Crisantomas D. Guno: The Court found that the service of summons upon Carmelita was binding on Crisantomas. The action was an action in personam concerning documents entered into during their marriage, and their obligations were presumed to be under their conjugal partnership. Since they were married before the Family Code, the regime of conjugal partnership of gains governed their property relations, and all property acquired during the marriage is presumed conjugal unless proven otherwise. The Court reasoned that as the obligations were for the benefit of the conjugal partnership, they were correctly made co-defendants with the same interests. Therefore, the receipt of summons by Carmelita bound Crisantomas, as the core of due process was protected, and Crisantomas failed to prove separation in fact or annulment at the time of service. Given this finding, the Court deemed it unnecessary to discuss the correctness of the substituted service upon Crisantomas.
Main Doctrine
The receipt of summons by one spouse in an action in personam involving conjugal property is binding on the other spouse, provided that the marriage has not been annulled or the spouses are not separated in fact, and the defendant spouse fails to substantiate claims of non-receipt or lack of notice.