Case Summary (G.R. No. 203160)
Procedural Background
A demand letter for repair costs amounting to P567,070.68 was sent by Green Star to NURC, which was denied on the grounds that the liability would be determined in the pending criminal case. After the dismissal of the criminal case, Green Star and Sayson instituted a complaint for damages against NURC in the Regional Trial Court (RTC) of San Pedro, Laguna. Following the receipt of the summons by an NURC employee, NURC filed a Motion to Dismiss, arguing that the RTC lacked jurisdiction due to improper service of summons.
Regional Trial Court's Ruling
On May 5, 2004, the RTC denied NURC's motion to dismiss, ruling that there was "substantial compliance" with service procedures as NURC had actual receipt of the summons. NURC subsequently filed a Petition for Certiorari with the Court of Appeals (CA), challenging the RTC's decision.
Court of Appeals Decision
On September 17, 2007, the CA reversed the RTC's ruling, granting NURC's Petition for Certiorari and dismissing the complaint for lack of jurisdiction. The CA concluded that the summons was not served properly in accordance with Rule 14 of the 1997 Rules of Court, which outlines the required manner of serving summons on domestic private juridical entities.
Issue of Jurisdiction
The core issue before the Supreme Court was whether the summons was adequately served to vest the RTC with jurisdiction over NURC. The Supreme Court emphasized that strict compliance with the rules on service of summons is imperative for a court to acquire jurisdiction over a defendant.
Legal Provisions on Service of Summons
According to Section 11, Rule 14 of the 1997 Rules of Court, summons can only be served on the president, managing partner, general manager, corporate secretary, treasurer, or in-house counsel of a corporation. The previous rule permitted wider categories of individuals, including agents of the corporation, thereby highlighting a significant narrowing of the list in the revised rules.
Findings on Service of Summons
In this case, the summons was received by Francis Tinio, NURC's cost accountant. Green Star attempted to argue that this was valid service contend
...continue readingCase Syllabus (G.R. No. 203160)
Case Background
- The case revolves around a vehicular accident on February 25, 2003, between a Mitsubishi L-300 van owned by Universal Robina Corporation (URC) and a passenger bus operated by Green Star Express, Inc.
- The accident resulted in the death of the van's driver, leading to the bus driver, Fruto Sayson, Jr., being charged with reckless imprudence resulting in homicide.
- Following the incident, Green Star demanded payment for repairs totaling P567,070.68 from Nissin-Universal Robina Corporation (NURC), which was denied, citing that the criminal case would determine liabilities.
- The criminal case was eventually dismissed due to insufficient evidence.
- Subsequently, Green Star and Sayson filed a complaint for damages against NURC before the Regional Trial Court (RTC) of San Pedro, Laguna.
Procedural History
- NURC's employee, Francis Tinio, received the summons related to the case.
- On February 6, 2004, NURC filed a Motion to Dismiss the case, claiming lack of jurisdiction due to improper service of summons.
- The RTC issued a Resolution on May 5, 2004, denying NURC's motion, stating there was substantial compliance as NURC had actual receipt of the summons.
- NURC's subsequent Petition for Certiorari to the Court of Appeals (CA) s