G.R. No. 168723 - DOLE PHILIPPINES, INC. vs. QUILALA

A complaint was filed by private respondent All Season Farm Corporation seeking the recovery of money, accounting, and damages against Dole Philippines, Inc. (Tropifresh Division) and several of its officers.
The complaint was filed with the Regional Trial Court (RTC) of Makati City, Branch 150, presided over by Pairing Judge Reinato G. Quilala.

Dole contended that the alias summons was improperly served.
According to Dole, the summons was served via Marifa Dela Cruz, a legal assistant employed by Dole Pacific General Services, Ltd.—a separate entity from Dole.
Dole maintained that for proper jurisdiction, the summons had to be served directly on the designated corporate officers stipulated in Section 11, Rule 14 of the 1997 Rules of Civil Procedure.

On May 20, 2003, Dole filed a motion to dismiss the complaint on multiple grounds:

Lack of jurisdiction over its person due to improper service of summons.
Failure of the complaint to state a cause of action.
Allegation that All Season was not the real party in interest.
Assertion that Dole’s officers could not be sued in their personal capacities for acts performed as corporate officers.

The RTC, via its Order dated February 6, 2004, denied Dole’s motion to dismiss.
A motion for partial reconsideration by Dole was also denied by the RTC.
Dole subsequently elevated the case by filing a petition for certiorari with the Court of Appeals, challenging the proper service of the alias summons.

The appellate court found that Dole’s president was made aware of the service even if he did not personally receive/sign the summons.
The Court of Appeals noted that, in the modern corporate context, documents addressed to corporate officers can be duly received on their behalf by their staff.
Dole’s subsequent filing of an Entry of Appearance with a Motion for Time on May 5, 2003 was considered an acknowledgment of receipt of the summons and a submission to the RTC’s jurisdiction.

Petitioner (Dole) raised a single issue: whether the Court of Appeals erred in holding that substituted service on a private corporation was valid even though the summons was not served on any of the corporate officers designated under Section 11, Rule 14.
Dole argued that the service on Marifa Dela Cruz, an employee who is not among the enumerated officers, did not suffice for valid service of summons.
Private respondent All Season contended that the service was valid as the summons was effectively received by Dole’s president through the chain of command and subsequent voluntary appearance.

Whether there was a valid service of summons on Dole Philippines, Inc., a domestic private corporation, particularly when the alias summons was served on an employee rather than on one of the corporate officers specifically enumerated under Section 11, Rule 14 of the 1997 Rules of Civil Procedure.
Whether Dole’s voluntary appearance, which included the filing of an Entry of Appearance with a Motion for Time, constitutes an acceptance of jurisdiction that ultimately waives any objections on the ground of improper service.