G.R. No. 147937 - The Philippine American Life and General Insurance Company vs. Breva

The petitioner is The Philippine American Life & General Insurance Company, a domestic corporation organized under Philippine laws with its principal office at the Philamlife Building, United Nations Avenue, Ermita, Manila, and a regional office in Davao City.
The respondents comprise Hon. Augusto V. Breva, in his capacity as Presiding Judge of the Regional Trial Court (RTC) of Davao City, Branch 10, and Milagros P. Morales, who initiated the litigation.

On September 22, 1999, respondent Milagros P. Morales filed a complaint for damages and reimbursement of insurance premiums against the petitioner in the RTC of Davao City, Branch 10 (Civil Case No. 27554-99).
The complaint specified that service could be effected through the petitioner’s Davao regional office.

A summons dated September 29, 1999, along with the complaint, was served on the petitioner’s Davao branch office and received by its Insurance Service Officer, Ruthie Babael, on November 19, 1999.
On December 8, 1999, the petitioner moved to dismiss the complaint on the ground of lack of jurisdiction over its person, arguing that service on an employee at the regional office did not comply with Section 11, Rule 14 of the 1997 Rules of Civil Procedure.

On December 9, 1999, respondent Morales filed an amended complaint asserting that service could also be effected at the petitioner’s principal office in Manila through its president or any duly authorized officer.
On December 10, 1999, the RTC issued an order denying the motion to dismiss and directed the issuance of an alias summons to be served at the petitioner’s principal office.

On January 12, 2000, the petitioner filed a motion for reconsideration of the RTC’s order.
On December 14, 1999, the petitioner received an alias summons along with a copy of the amended complaint.
On January 14, 2000, the RTC denied the petitioner’s motion for reconsideration and the supplemental oral motion to strike out the amended complaint, emphasizing that the remedy to address service defects was the issuance of a new summons on the amended complaint.

On March 2, 2000, the petitioner elevated the matter by filing a special action for certiorari and prohibition with the Court of Appeals (CA), seeking a writ of preliminary injunction and/or a temporary restraining order.
On October 24, 2000, the CA dismissed the petition, affirming the RTC’s orders that had denied the petitioner's motion to dismiss.
On April 25, 2001, the CA also denied the petitioner’s subsequent motion for reconsideration.

The petitioner contended that the RTC abused its discretion by denying its motion to dismiss on the grounds of lack of jurisdiction, asserting that the service of summons via an unauthorized employee rendered the service defective.
The petitioner further argued that the issuance of an alias summons was procedurally flawed since the rules prescribed its issuance only when a previous summons was lost or unserved.
In contrast, respondent Morales maintained that the receipt of the alias summons with the amended complaint remedied any defects in the original service, ensuring that adequate notice was provided in accordance with the rules.

Whether the trial court committed grave abuse of discretion in denying the petitioner’s motion to dismiss for lack of jurisdiction over its person due to the alleged improper service of summons.
Whether the trial court acquired proper personal jurisdiction over the petitioner through the service of an alias summons on the amended complaint, notwithstanding the initial defect in service.