Case Digest (G.R. No. 185891) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Perkin Elmer Singapore Pte Ltd. vs. Dakila Trading Corporation, decided on August 14, 2007, respondent Dakila Trading Corporation (Dakila), a Philippine corporation, entered into a Distribution Agreement on June 1, 1990 with Perkin-Elmer Instruments Asia, Pte Ltd. (PEIA), a Singaporean corporate entity engaged in the sale and distribution of laboratory instruments. Under the agreement Dakila was appointed sole distributor in the Philippines and entitled to commissions on sales. PEIA allegedly owned 99% of Perkin-Elmer Instruments (Philippines) Corporation (PEIP), a separate Philippine affiliate. On August 2, 1997 PEIA unilaterally terminated the agreement, prompting Dakila to file, on March 26, 1999, a complaint for collection of sums and damages with prayer for writ of attachment against PEIA and PEIP before the Mandaluyong RTC, Branch 212 (Civil Case No. MC99-605). The RTC denied the writ of attachment and Dakila’s motion for reconsideration. It later granted Dakila leave t Case Digest (G.R. No. 185891) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Distribution Agreement
- Perkin Elmer Singapore Pte. Ltd. (“petitioner”) is a Singaporean corporation, alleged owner of Perkin-Elmer Instruments Asia Pte. Ltd. (PEIA).
- Dakila Trading Corporation (“respondent”) is a Philippine corporation appointed sole distributor of PEIA products in the Philippines under a 1 June 1990 Distribution Agreement, with rights to purchase from PEIA or its affiliate PEIP (Perkin-Elmer Instruments (Philippines) Corporation).
- Termination and Initial Proceedings
- On 2 August 1997 PEIA unilaterally terminated the Distribution Agreement. Respondent filed Civil Case No. MC99-605 in RTC Mandaluyong Branch 212 for collection of money, damages, and issuance of writ of attachment against PEIA and PEIP.
- RTC denied the writ of attachment (26 March 1999; 11 January 2000). Respondent secured leave to effect extraterritorial service of summons.
- Amended Complaint and RTC Orders
- Alias summons was mis-served on Perkinelmer Asia (a sole proprietorship) instead of PEIA. PEIP moved to dismiss; Perkinelmer Asia disputed jurisdiction.
- Respondent filed an Amended Complaint (alleging PEIA became sole proprietorship of petitioner, renamed Perkinelmer Asia) and successfully changed defendant’s name (Order, 24 July 2001).
- RTC deputized respondent’s GM to serve summons in Singapore (Order, 4 March 2002). Petitioner filed Special Appearance and Motion to Dismiss (30 May 2002) on grounds of lack of personal jurisdiction, misjoinder, failure to state cause of action, and improper venue. RTC denied these motions (Orders, 4 November 2002; 20 June 2003).
- Appeals and Supreme Court Petition
- Petitioner sought certiorari with injunction in CA; CA issued no injunction but affirmed RTC on 4 April 2006.
- Petitioner filed a Rule 45 petition before the Supreme Court raising issues on summons service, cause of action, venue, and injunctive relief.
Issues:
- Whether service of summons was defective and the RTC lacked personal jurisdiction over petitioner.
- Whether the CA erred by limiting certiorari review to jurisdiction and refusing relief on cause of action and venue.
- Whether petitioner is entitled to a temporary restraining order or writ of injunction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)