Case Digest (G.R. No. 204753) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On November 27, 2006, United Coconut Planters Bank (UCPB) filed Civil Case No. 06-1014 before the Regional Trial Court (RTC) of Makati City, Branch 146, for sum of money and damages against Nation Granary, Inc. (NGI), Nation Petroleum Gas, Inc. (NPGI), and the spouses Alison Ang-Sy and Guillermo Sy, Renato Ang, Nena Ang, Ricky Ang, and Derick Chester Sy (collectively, respondents). UCPB alleged it extended credit accommodations to NGI secured by surety agreements executed by both corporations and the spouses. On November 30, 2006, the RTC issued an ex parte writ of preliminary attachment; summons and copies of the order were served on December 4, 2006, by the sheriff, who levied a Toyota Land Cruiser, and garnishment followed on December 5, 2006. On December 18, 2006, respondents moved to dismiss for lack of personal jurisdiction, arguing defective service of summons—corporate defendants were served through a mere custodian of property and the spouses were not personally served Case Digest (G.R. No. 204753) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Complaint and Underlying Transaction
- On 27 November 2006, United Coconut Planters Bank (UCPB) filed a Complaint for sum of money and/or damages with prayer for ex parte issuance of a writ of preliminary attachment against:
- Nation Granary, Inc. (NGI)
- Spouses Alison Ang-Sy and Guillermo Sy, Renato Ang, Nena Ang, Ricky Ang and Derick Chester A. Sy (collectively, respondents)
- Nation Petroleum Gas, Inc. (NPGI)
- The Complaint alleged that on 28 August 2005, UCPB granted NGI the following credit accommodations:
- Import Letter of Credit/Trust Receipt Line of US$15,000,000.00
- Case-to-case Letter of Credit/Trust Receipt of US$3,800,400.00
- Ex Parte Attachment and Service of Summons
- On 30 November 2006, the Regional Trial Court (RTC) of Makati City, Branch 146, granted UCPB’s prayer for a writ of preliminary attachment.
- On 4 December 2006, summonses and copies of the attachment order were served:
- Personal service attempts (one day only) on respondents and NGI/NPGI.
- The Sheriff levied a Toyota Land Cruiser (plate XRK-783) reportedly owned by respondents.
- On 5 December 2006, respondents’ shares and other assets in NGI and NPGI were garnished.
- Motion to Dismiss and RTC Ruling
- On 18 December 2006, respondents filed a Motion to Dismiss with Manifestation, alleging:
- Defective service of summons — served on a mere employee (Charlotte Magpayo), not an authorized corporate officer.
- No personal service first resorted to before substituted service on the spouses.
- On 8 June 2007, the RTC:
- Granted suspension of proceedings as to NGI and NPGI (due to a separate Stay Order).
- Denied the Motion to Dismiss for lack of jurisdiction.
- Respondents’ motion for reconsideration was denied; they then filed a Rule 65 petition for certiorari before the Court of Appeals (CA).
- CA Decision, Resolution and Appeal to the Supreme Court
- On 10 February 2012, the CA granted respondents’ Rule 65 petition, holding that:
- Service of summons was defective and the RTC acquired no jurisdiction.
- All RTC proceedings and orders were void.
- On 7 December 2012, the CA denied UCPB’s Motion for Reconsideration.
- UCPB filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, challenging:
- The CA’s finding that the RTC lacked jurisdiction over the defendant corporations.
- The CA’s finding that the RTC lacked jurisdiction over the spouses Sy.
Issues:
- Jurisdiction Over Defendant Corporations
- Did the CA err in finding that the RTC lacked jurisdiction over NGI and NPGI, even though they did not challenge the RTC Order before the CA?
- Jurisdiction Over Individual Respondents
- Did the CA err in finding that the RTC lacked jurisdiction over the persons of spouses Alison Ang-Sy and Guillermo Sy, Renato Ang, Nena Ang, Ricky Ang and Derick Chester A. Sy?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)