Title
St. Aviation Services Co., Pte., Ltd. vs. Grand International Airways, Inc.
Case
G.R. No. 140288
Decision Date
Oct 23, 2006
A Singapore court's default judgment against a Philippine airline for unpaid aircraft maintenance fees was upheld by the Philippine Supreme Court, ruling the extraterritorial service of summons valid and the foreign judgment enforceable under Philippine law.

Case Digest (G.R. No. 140288)

Facts:

St. Aviation Services Co., Pte., Ltd. v. Grand International Airways, Inc., G.R. No. 140288, October 23, 2006, Supreme Court Second Division, Sandoval-Gutierrez, J., writing for the Court.

Petitioner is St. Aviation Services Co., Pte., Ltd., a Singapore-based foreign corporation engaged in aircraft maintenance and repair. Respondent is Grand International Airways, Inc., a Philippine domestic airline corporation. In January 1996 the parties entered into an Agreement for the Maintenance and Modification of Airbus A300 B4-103 Aircraft Registration No. RP-C8882 (the First Agreement), which provided that the “construction, validity and performance” of the contract would be governed by Singapore law and that suits could be submitted to the non-exclusive jurisdiction of the Singapore courts. At about the same time the parties reached a verbal agreement (based on a General Terms of Agreement) for maintenance on another aircraft, RP-C8881, on similar terms.

Petitioner performed the contracted works and billed respondent a total of US$303,731.67 (S$452,560.18) for services rendered from March 1996 to October 1997. Despite repeated demands, respondent failed to pay. On December 12, 1997 petitioner filed Suit No. 2101 in the High Court of the Republic of Singapore for S$452,560.18, with interest and costs. The Singapore court granted petitioner leave to serve the writ extraterritorially, and instructed that service be effected by a method authorized by Philippine law. The writ was served in the Philippines by the sheriff at respondent’s office (receipt shown May 2, 1998) but respondent did not answer, and on February 17, 1998 the Singapore High Court entered judgment by default.

On August 4, 1998 petitioner filed in the Regional Trial Court (RTC), Branch 117, Pasay City, a Petition for Enforcement of Judgment (Civil Case No. 98-1389). Respondent moved to dismiss the petition on two grounds: (1) lack of personal jurisdiction in the Singapore court because of defective extraterritorial service; and (2) violation of due process rendering the foreign judgment void. The RTC denied the motion to dismiss on October 30, 1998 and denied reconsideration on December 16, 1998.

Respondent filed a petition for certiorari with the Court of Appeals (CA) on February 15, 1999, challenging the RTC’s denial; the CA granted respondent’s petition in a July 30, 1999 Decision (denied reconsideration Sept. 29, 1999), holding that ...(Pro-only)

Issues:

  • Did the Singapore High Court acquire jurisdiction over Grand International Airways, Inc. by service of the writ upon its office in the Philippines?
  • Is the default judgment rendered by the Singapore High Court in Suit No. 2101 enforceable in...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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