Case Digest (G.R. No. 6516) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Agapita Trajano, et al. v. Imelda “Imee” Marcos-Manotoc, Civil Case No. 63337, filed June 25, 1993 before the Regional Trial Court (RTC) of Pasig City, respondent sought enforcement in the Philippines of a May 1, 1991 Honolulu, Hawaii judgment for wrongful death of Archimedes Trajano. The RTC issued summons on July 6, 1993 addressed to petitioner at “Alexandra Homes, E2 Room 104, No. 29 Meralco Avenue, Pasig City.” According to the sheriff’s Return dated July 15, 1993, after “many occasions” of unsuccessful personal service, substituted service was effected by leaving the summons with “Mr. Macky de la Cruz, caretaker,” whom a building receptionist identified as a person of “suitable age and discretion.” When no Answer was filed, the RTC declared petitioner in default October 13, 1993. Thereafter, by special appearance she moved to dismiss for lack of jurisdiction, alleging invalid substituted service: the address was not her residence, the recipient was not a resident or agen... Case Digest (G.R. No. 6516) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- Petitioner Ma. Imelda “Imee” Marcos-Manotoc is the defendant in Civil Case No. 63-337 filed by Agapita Trajano on behalf of the Estate of Archimedes Trajano for enforcement of a May 1, 1991 U.S. District Court (Honolulu) judgment in a wrongful death suit against military intelligence officials allegedly under Manotoc’s command.
- Trial court issued summons on July 6, 1993, addressed to Alexandra Condominium Corporation (Alexandra Homes), E-2 Room 104, No. 29 Meralco Avenue, Pasig City.
- Service of Summons and Motion to Dismiss
- On July 15, 1993, the sheriff allegedly effected substituted service by leaving the summons with “Mr. Macky de la Cruz, caretaker,” per a receptionist’s declaration. Return stated multiple failed personal attempts “at reasonable hours” but gave no dates or details.
- Petitioner failed to answer and was declared in default (Oct. 13, 1993). She then filed a special appearance motion to dismiss for lack of personal jurisdiction, asserting:
- The address was not her residence or place of business;
- De la Cruz was not her representative nor resident;
- Procedural rules on substituted service were ignored;
- She was a resident of Singapore;
- Any judgment would be futile.
- At hearing, petitioner presented testimony and documentary proof (witness Gonzales, condominium ownership certification, Philippine passport, Singapore embarkation card) to show nonresidence at the address; respondent produced logbook entries, testimony of Atty. Robert Swift, and the sheriff’s return.
- Trial Court and Court of Appeals Proceedings
- Trial court (Oct. 11 & Dec. 21, 1994) denied petitioner's motion, presuming the sheriff’s substituted service valid and concluding that Alexandra Homes was petitioner’s residence.
- Petitioner sought certiorari in the Court of Appeals (CA-G.R. SP No. 36214). On March 17, 1997, CA dismissed her petition, ruling the service valid under Section 8, Rule 14 of the old Rules of Court, and finding hearsay objections to petitioner’s evidence unavailing. CA denied reconsideration on October 8, 1997.
Issues:
- Whether the substituted service of summons on petitioner complied with the requisites of Section 8, Rule 14 (old Rules of Court) to vest jurisdiction in the trial court.
- Whether the CA erred in upholding the presumption of regularity of official duty despite defects in the sheriff’s Return.
- Whether petitioner’s nonresidence at the address and the identity of the recipient defeated jurisdiction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)