Case Summary (G.R. No. 184333)
Factual Background
Sixto N. Chu, engaged in business, entered into a series of installment purchases with Mach Asia Trading Corporation, acquiring heavy machinery totaling P1,900,000. Chu made an initial payment but subsequently experienced financial difficulties due to the Asian economic crisis, leading to dishonored checks presented by the respondent. After attempts to settle his debts, Chu did not remedy the situation, prompting Mach Asia Trading to file a complaint in the Regional Trial Court (RTC) for the sum of money, replevin, attorney’s fees, and damages.
Judicial Proceedings
The RTC of Cebu City granted Mach Asia's request for replevin, allowing seizure of the machinery. The sheriff attempted to serve a summons to Chu, but personal service was not achieved; instead, it was served through Rolando Bonayon, a security guard at Chu's premises. Lacking any responsive pleading from Chu, the RTC declared him in default and ruled in favor of Mach Asia, affirming its ownership of the machinery and awarding attorney’s fees and litigation costs.
Court of Appeals Decision
Chu appealed the RTC decision to the Court of Appeals, asserting that the substituted service of summons was invalid and unconstitutional, as it did not meet the legal standards for such an action. The CA upheld the RTC's decision, reasoning that Chu received due process since the summons reached him via his security guard. Moreover, it maintained that Chu failed to present a valid defense for his financial obligations.
Legal Analysis of Summons and Jurisdiction
The Supreme Court examined the validity of the substituted service. Per the Rules of Court, substituted service is permissible when personal service has been attempted without success. However, strict compliance with the statutory requirements is mandated since such service deviates from the usual process. It was determined that the service through the security guard did not satisfy the requirement that the individual must possess a relation of confidence with the defendant, nor was it demonstrated that efforts to serve Chu personally were adequately pursued.
Ruling on Due Process
The Supreme Court reiterated the significance of proper summons in establishing jurisdiction over the defendant. A judgment is deemed null and void if a court lacks jurisdiction due to improper service. In this case, the service of summons to Chu was ruled inadequate, which meant that the prior judgments against him wer
...continue readingCase Syllabus (G.R. No. 184333)
Case Background
- The case involves a petition for review on certiorari filed by Sixto N. Chu against Mach Asia Trading Corporation.
- The petition challenges the Decision issued by the Court of Appeals (CA) on June 25, 2007, and the subsequent Resolution denying the Motion for Reconsideration on August 28, 2008.
- The core issue revolves around the validity of service of summons and the jurisdiction of the Regional Trial Court (RTC) over the petitioner.
Factual Antecedents
- Mach Asia Trading Corporation is engaged in importing heavy equipment, including dump trucks.
- On December 8, 1998, Sixto N. Chu purchased a Hitachi Excavator for P900,000.00, making an initial payment of P180,000.00 and agreeing to pay the remaining balance in 12 monthly installments via postdated checks.
- On March 29, 1999, he purchased additional equipment (a motorgrader and a payloader) for P1,000,000.00, making a down payment of P200,000.00 with a similar payment plan.
- The checks issued for these payments were dishonored due to reasons such as closed accounts and insufficient funds.
- Respondent sent a formal demand letter on September 16, 1999, requesting payment within five days.
- Chu responded, citing financial difficulties due to the Asian economic crisis and offered to make partial payments or return the equipment.
Procedural History
- On November 11, 1999, Mach Asia filed a complaint in the RTC of Cebu City for sum of money, replevin, attorney’s fees, and damages, claiming an unpaid balance of P1,661,947.27.
- The RTC allowed a writ of repl