G.R. No. 163584 - Robinson vs. Miralles

On August 25, 2000, Celita B. Miralles (respondent) filed a complaint against Remelita M. Robinson (petitioner) for the sum of US$20,054.00.
The complaint was based on a Memorandum of Agreement dated January 12, 2000, whereby petitioner allegedly borrowed the said amount from respondent.
The case was docketed as Civil Case No. 00-0372 before the Regional Trial Court (RTC), Branch 274, Parañaque City.

Summons was initially served at petitioner’s given address but it was returned unserved because petitioner no longer resided there.
On July 20, 2001, an alias summons was issued to be served at petitioner’s new address at No. 19 Baguio St., Alabang Hills, Muntinlupa City.
Service attempts failed because the subdivision’s security guard, A.H. Geroche, refused to allow the sheriff entry to personally serve the summons.
The security guard stated petitioner instructed that no one be allowed inside to serve summons if she was not around.
The sheriff left the summons and complaint with the security guard, who refused to sign the receipt.

Respondent moved to declare petitioner in default for failing to file an answer.
On February 28, 2003, the RTC granted the motion, declared petitioner in default, and allowed respondent to present evidence ex parte.
On June 20, 2003, the RTC rendered judgment ordering petitioner to pay respondent:

US$20,054.00 plus stipulated interest of 3% per month from May 2000 until fully paid;
Php100,000.00 for moral damages;
Php50,000.00 plus Php1,500.00 per appearance as attorney’s fees;
Costs of suit.

A copy of the judgment was mailed by registered mail to petitioner’s new address.
A writ of execution was issued on September 8, 2003.

On September 26, 2003, petitioner filed a petition for relief from the judgment, contending that summons was never properly served and that the court lacked jurisdiction.
The RTC denied the petition in Resolutions dated February 11 and May 11, 2004.
Petitioner then filed a petition for review on certiorari assailing the RTC's resolutions.

Whether or not the trial court correctly ruled that substituted service of summons on petitioner through the subdivision security guard was valid and sufficient to confer jurisdiction over petitioner.