G.R. No. 202505 - Express Padala vs. Ocampo

EXPRESS PADALA (ITALIA) S.P.A., NOW BDO REMITTANCE (ITALIA) S.P.A. employed HELEN M. OCAMPO as a remittance processor in September 2002.
Ocampo was dismissed in February 2004 for alleged misappropriation of PHP 24,035.60 by falsifying invoices for customers' money transfer orders from February to December 2003.
BDO Remittance filed a criminal complaint in the Court of Turin, Italy; Ocampo pleaded guilty.
On April 13, 2005, the Court of Turin convicted Ocampo, sentenced her to six months' imprisonment and a fine of 300.00, but granted suspension of the enforcement of sentence (the Court of Turin Decision).

On September 22, 2008, BDO Remittance filed a petition for recognition of foreign judgment with the Regional Trial Court (RTC) of Mandaluyong City, praying recognition of the Court of Turin Decision and cancellation or restriction of Ocampo's Philippine passport by the Department of Foreign Affairs (DFA).
On November 21, 2008, the sheriff attempted personal service at Ocampo's alleged local address in San Bernardo Village, Darasa, Tanauan, Batangas; the address proved incomplete.
Barangay officials directed the sheriff to the house of Ocampo's father; Victor P. Macahia, Ocampo's uncle and present occupant, informed the sheriff that Ocampo and her family were already in Italy and that he was caretaker.
The sheriff served the summons on Macahia by substituted service.
Ocampo did not file an answer; BDO Remittance moved to declare her in default; the RTC granted the motion and allowed ex parte presentation of evidence.

RTC judgment, subsequent notice, and procedural history in the Court of Appeals

On September 14, 2009, the RTC rendered a Decision recognizing the Court of Turin Decision and ordering the DFA to cancel or restrict Ocampo's passport and bar renewal until she served her sentence.
On February 11, 2010, Ocampo's mother received a copy of the RTC Decision and forwarded it to Ocampo.
Ocampo failed to appeal within the period; she later engaged counsel and filed a petition for certiorari under Rule 65 with the Court of Appeals (CA) on April 12, 2010.
The CA granted Ocampo's petition, set aside the RTC Decision, and revoked the passport-cancellation order, holding that substituted service was improper because Ocampo's whereabouts were unknown and service should have been by publication under Rule 14, Sec. 14; the CA concluded the RTC lacked jurisdiction and its Decision was null and void....(Subscriber-Only)

Whether service of summons was validly effected upon HELEN M. OCAMPO by substituted service through her uncle at her former Philippine residence, thereby vesting the RTC with jurisdiction over her person.

Whether the RTC gravely abused its discretion in recognizing a foreign criminal judgment and ordering the DFA to cancel or restrict Ocampo's Philippine passport.
Whether Ocampo availed of the wrong remedy in seeking relief b...(Subscriber-Only)