People's General Insurance v. Guansing
REITERATIONFacts
The Antecedents: On February 4, 2006, Eduardo Lizaso, an employee of Edgardo Guansing, was driving Guansing's truck and hit the rear of Andrea Yokohama's Isuzu Crosswind. The impact caused the Isuzu Crosswind to hit other vehicles, rendering it beyond repair. Yokohama's vehicle was insured with People's General Insurance Corporation (People's General), which paid Yokohama P907,800.00. People's General, claiming subrogation, sought reimbursement from Guansing for the amount paid, less salvage value. Guansing failed to reimburse. Procedural History: People's General filed a collection case against Guansing and Lizaso. Summons was served on Guansing's brother, Reynaldo Guansing, with the sheriff's return stating Reynaldo was of sufficient discretion. The return did not explain why summons was not personally served on Edgardo Guansing. Guansing filed a Motion to Dismiss for lack of jurisdiction, which was denied. He filed an Answer, reiterating the lack of jurisdiction. He also filed a Pre-trial Brief, again raising the issue of jurisdiction. The Regional Trial Court (RTC) granted People's General's Motion to Render Judgment on the Pleadings and ruled in favor of People's General. Guansing moved for reconsideration, reiterating the jurisdictional issue, which was denied. Guansing appealed to the Court of Appeals (CA). The CA set aside the RTC Decision, ruling that summons was improperly served and the RTC did not acquire jurisdiction over Guansing. The CA remanded the case for valid service of summons. The Petition: People's General filed a Petition for Review on Certiorari before the Supreme Court, arguing that the CA erred in holding that Guansing's filing of an Answer and other pleadings did not constitute voluntary appearance, and thus, the RTC acquired jurisdiction over his person.
Issue(s)
Whether or not the Regional Trial Court acquired jurisdiction over the person of respondent Edgardo Guansing through service of summons. Whether or not respondent Edgardo Guansing, in filing his Answer and other subsequent pleadings, voluntarily submitted himself to the jurisdiction of the court.
Ruling
The Supreme Court granted the petition, reversed the Court of Appeals' Decision, and affirmed the Regional Trial Court's Decision. It held that while the service of summons was defective, Edgardo Guansing voluntarily submitted himself to the jurisdiction of the court by filing an Answer and other subsequent pleadings, which cured the defect and vested the RTC with jurisdiction.
Ratio Decidendi
On the first issue of jurisdiction through service of summons: The Court reiterated that personal service is the preferred mode of service of summons, and substituted service is an exception. For substituted service to be valid, the sheriff's return must contain a detailed enumeration of the sheriff's actions showing diligent and reasonable efforts to serve the defendant personally, and the impossibility of prompt personal service. In this case, the sheriff's return was defective because it did not provide specific details of attempts to serve summons personally on Edgardo Guansing, nor did it explain the impossibility of such service. The return merely stated that summons was served on his brother, Reynaldo Guansing, who was of sufficient discretion. The presumption of regularity in the performance of official duty does not apply to patently defective returns. Therefore, the initial service of summons was indeed invalid, and the RTC did not acquire jurisdiction over Guansing's person through this defective service. On the second issue of voluntary appearance: The Court held that despite the defective service of summons, Edgardo Guansing voluntarily submitted himself to the jurisdiction of the court by filing an Answer, a Pre-trial Brief, an Urgent Ex-Parte Motion for Postponement, a Motion for Reconsideration, and a Notice of Appeal. These actions constitute voluntary appearance, which is equivalent to service of summons under Rule 14, Section 20 of the Rules of Court. By participating in the proceedings and seeking affirmative reliefs, Guansing waived any objection to the court's jurisdiction over his person. The Court distinguished this case from Garcia v. Sandiganbayan, emphasizing that Guansing's pleadings were not solely for the purpose of challenging jurisdiction but also involved participation in the merits of the case and seeking affirmative actions. The Court stressed that technicalities should not be used to impede justice, and Guansing's active participation cured the defect in the summons.
Main Doctrine
While a defective sheriff's return may render substituted service invalid, a defendant's subsequent voluntary appearance through the filing of pleadings and seeking affirmative reliefs cures any defect in the service of summons, thereby vesting the court with jurisdiction over the person.