Facts:

• Petitioner Leoncio Sy appealed to the Court of Appeals after being convicted of criminal negligence.
• In a separate civil action, private respondent Severino Ruaro sued Sy for damages in the Court of First Instance of Ilocos Norte.
• A default judgment was rendered against Sy in the civil case.
• However, there was no proper service of summons on Sy.
• It was uncertain if the requirements for substituted service of summons were complied with.
• Sy moved to vacate the judgment, but the trial court denied the motion.
• The Court of Appeals later acquitted Sy of criminal liability.
• Sy moved to reconsider the trial court's order denying his motion, but the trial court denied it, stating that its judgment had already become final.

Issue:

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Ruling:

• The trial and judgment without proper service of summons are null and void.
• The default judgment in the civil case is set aside.
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Ratio:

• The Supreme Court held that trial and judgment without proper service of summons are null and void.
• In this case, there was no personal service of summons on Sy and it was uncertain if the requirements for substituted service were met.
• Therefore, the trial court did not acquire jurisdiction over Sy's person.
• Furthermore, the Court of Appeals' judgment of acquittal contradicted the defaul...continue reading