Facts:

The case involves Ma. Imelda M. Manotoc as the petitioner and Agapita Trajano, on behalf of the estate of Archimedes Trajano, as the respondent. The events leading to this case began with Civil Case No. 63337, filed by Agapita Trajano in the Regional Trial Court of Pasig City, seeking the enforcement of a foreign judgment rendered by the United States District Court of Honolulu, Hawaii, on May 1, 1991. This judgment pertained to a wrongful death claim against Manotoc, allegedly committed by military intelligence officials of the Philippines under her command. The trial court issued a summons on July 6, 1993, addressed to Manotoc at her alleged residence in Alexandra Homes, Pasig City. The summons was reportedly served on July 15, 1993, to a caretaker named Macky de la Cruz. When Manotoc failed to respond, the trial court declared her in default on October 13, 1993. Subsequently, she filed a Motion to Dismiss on October 19, 1993, arguing that the court lacked jurisdiction due ...

Facts:

Background of the Case

The case involves a Petition for Review on Certiorari filed by Ma. Imelda M. Manotoc, challenging the validity of the substituted service of summons in Civil Case No. 63337. The respondents, represented by Agapita Trajano, sought the enforcement of a foreign judgment from the United States District Court of Honolulu, Hawaii, against Manotoc for the wrongful death of Archimedes Trajano.

Service of Summons

On July 6, 1993, the trial court issued a summons addressed to Manotoc at Alexandra Condominium Corporation, Pasig City. On July 15, 1993, the summons and a copy of the complaint were allegedly served on Macky de la Cruz, described as a caretaker at the condominium unit. Manotoc failed to file an answer, leading to her being declared in default on October 13, 1993.

Manotoc’s Motion to Dismiss

Manotoc, through her counsel, filed a Motion to Dismiss on October 19, 1993, arguing that the substituted service of summons was invalid. She contended that the address in the summons was not her dwelling, residence, or regular place of business, and that de la Cruz was not her representative, employee, or resident. She also claimed residency in Singapore.

Trial Court’s Decision

The trial court rejected Manotoc’s Motion to Dismiss on October 11, 1994, ruling that Alexandra Homes was her residence based on documentary evidence. The court presumed regularity in the sheriff’s service of summons.

Court of Appeals’ Decision

The Court of Appeals (CA) dismissed Manotoc’s Petition for Certiorari and Prohibition on March 17, 1997, affirming the trial court’s finding that Alexandra Homes was her residence and that the substituted service of summons was valid.

Issue:

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Ruling:

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Ratio:

1. Validity of Substituted Service: Substituted service of summons must strictly comply with Rule 14, Section 8 requirements, including impossibility of prompt personal service, specific details in the Sheriff’s Return, and service on a person of suitable age and discretion residing with the defendant.
2. Defective Sheriff’s Return: The Sheriff’s Return in this case was deficient as it lacked specific details on the attempts to personally serve Manotoc and did not establish de la Cruz’s qualifications to receive the summons.
3. Presumption of Regularity: The presumption of regularity in the sheriff’s performance of official duty does not apply when the Sheriff’s Return is defective.
4. Mootness of Residence Issue: The invalidity of the substituted service rendered the issue of Manotoc’s residence moot.