Case Digest (G.R. No. 206005)
Facts:
Survivors of Agrichemicals in Gensan (SAGING), Inc. v. Standard Fruit Company, G.R. No. 206005, April 12, 2023, Supreme Court Second Division, Leonen, J., writing for the Court. Petitioners are SAGING, its chair Arturo G. Luardo, and its members; respondents are several foreign fruit companies including Standard Fruit Company, Standard Fruit and Steamship Co., DOLE Food Company, Inc., DOLE Fresh Fruit Company, Inc., Del Monte Fresh Produce N.A. Inc., and Del Monte Tropical Fruit Co. (Del Monte Tropical Fruit Co. now Del Monte Fresh Produce Company).As narrated in the complaint, SAGING’s members (former Davao banana plantation workers) suffered illnesses and reproductive injuries from exposure in the 1970s–1980s to nematocide products containing dibromochloropropane (DBCP) and sued the foreign corporations for quasi‑delict damages. The association (then Davao Banana Plantation Workers Association of Tiburcia, Inc.) originally filed a complaint on October 10, 1998; the Court of Appeals dismissed that complaint without prejudice for improper service, and the Supreme Court entered judgment on appeal (docketed G.R. No. 165958‑59) on June 2, 2009.
SAGING and its members refiled their complaint on September 9, 2010. The Regional Trial Court (RTC), Branch 15, Davao City, granted pauper status and ordered issuance of summons to the foreign defendants through the Department of Foreign Affairs (DFA); the deputy sheriff reported extraterritorial issuance to DFA for consular service. The DOLE and Del Monte respondents moved to dismiss, arguing improper service (no valid extraterritorial/personal service), failure to state a cause of action because SAGING was not the real party in interest, prescription, and lack of pauper qualifications. Other named foreign defendants did not answer.
The RTC dismissed the complaint as to the moving foreign corporations, ruling (1) it lacked jurisdiction over their persons because service through the Philippine consulate/DFA was improper under Rule 14, Sec. 12 (the complaint allegedly failed to plead specific facts showing the corporations transacted business in the Philippines); and (2) the complaint failed to state a cause of action because SAGING, a juridical entit...(Subscriber-Only)
Issues:
- Was the RTC correct in finding it lacked jurisdiction over the foreign corporations because service of summons through the DFA/consulate was improper?
- Did the complaint fail to state a cause of action because SAGING is not the real party in interest and the individual claimants were inadequately named?
- Are petitioners’ claims barre...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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