G.R. No. 212562 - Angeles y Olano vs. People

Rapid City Realty and Development Corporation, the petitioner, filed a complaint in 2004 seeking the declaration of nullity of subdivision plans, mandamus, and damages.
The complaint, docketed as Civil Case No. 04-7350, was lodged at the Regional Trial Court (RTC) of Antipolo City, Branch 71.
The defendants, including Spouses Orlando Villa and Lourdes Paez-Villa (respondents), were named in the complaint.

After an initial failed attempt at personal service of summons by court process server Gregorio Zapanta, substituted service was undertaken.
Zapanta served the summons and copy of the complaint with its annexes to the respondents’ househelp.

The househelp refused to sign to acknowledge receipt and also declined to divulge her name.
Zapanta documented the incident in the Return of Summons, noting the absence of the defendants and the presence of two lady househelps at the respondents' address.

A subsequent attempt on September 27, 2004, again resulted in service to the same househelp who refused to acknowledge receipt as directed by the defendants.

Respondents failed to file their Answer following the substituted service.
Petitioner then filed a Motion to Declare Defendants (respondents) in Default, which the trial court granted by Order on May 3, 2005.
Over eight months later, on January 30, 2006, respondents filed a Motion to Lift the Order of Default, asserting that:

They had officially received all pertinent papers, including the Complaint and Annexes.
They were denied the opportunity to answer or defend themselves because copies of pleadings were not furnished, and they thus claimed a violation of due process.
They contested the allegation that the househelps, alleged to have refused service, had the authority to receive the documents.

The trial court, by Order dated July 17, 2006, set aside the initial Order of Default and granted respondents five days to file their Answer.
Respondents still did not file an Answer, prompting petitioner to file another Motion to declare them in default, which was granted by Order on February 21, 2007.

On April 18, 2007, respondents filed an Omnibus Motion for Reconsideration of the second default order and to vacate proceedings, contending that the RTC had not acquired personal jurisdiction due to invalid service.
The trial court denied the Omnibus Motion by Order on May 22, 2007 and proceeded to receive ex-parte evidence for petitioner.
Respondents later challenged these orders before the Court of Appeals through certiorari.

The Court of Appeals annulled the RTC’s orders declaring respondents in default for the second time, reasoning that:

Respondents, by filing their motions (including the Motion to Lift the Order of Default), had not exclusively made a special appearance solely to question jurisdiction.
Instead, they focused all their defenses on challenging the court’s jurisdiction without raising any defense to the merits of the petitioner’s claim.

Case law was cited noting that filing motions for affirmative relief (e.g., motions to admit answer, for additional time to file an answer, for reconsideration, and to lift default) is considered a voluntary submission to the court’s jurisdiction unless an unequivocal special appearance is made.
Petitioner argued that respondents, by filing the first Motion to Lift the Order of Default, had voluntarily submitted to the court’s jurisdiction.

The petition for review on certiorari reached the Supreme Court after the petitioner's motion for reconsideration was denied by the Court of Appeals.
The Supreme Court reviewed the issue of whether the respondents’ filing of their motions constituted a voluntary appearance and submission to the court’s jurisdiction.
Relying on Section 20 of Rule 14 of the Rules of Court and relevant jurisprudence, the Supreme Court held that a party’s filing of motions for affirmative relief is equivalent to a voluntary appearance.
The Court emphasized the distinction between a special appearance (which explicitly challenges jurisdiction) and a regular appearance (which implies submission to jurisdiction).
Consequently, the Supreme Court granted the petition, reversed and set aside the Court of Appeals’ decision, and remanded the case to the RTC of Antipolo City, Branch 71.

Whether the respondents’ filing of their motions, including the Motion to Lift the Order of Default, constituted a voluntary appearance thereby submitting themselves to the jurisdiction of the court.
Whether the trial court validly acquired personal jurisdiction over the respondents despite alleged irregularities in the service of summons.
Whether the proceedings and orders declaring respondents in default were proper given the contested method of service and the respondents’ claims of lack of due process.