Case Summary (G.R. No. 203298)
Factual Background
On July 22, 2008, Interlink initiated legal proceedings against Expressions and Bon Huan for unpaid lease obligations. Notices to the respondents were personally served, but respondents contended that such service was defective, leading to Interlink's motion to declare them in default in January 2009. The RTC initially denied this motion, citing improper service of summons, and ordered a new service.
Service of Summons and Court Jurisdiction
The sheriff performed a second service of summons, but it was delivered to Amee Ochotorina, identified as a secretary, rather than Bon Huan, the president. Respondents argued this service was invalid, and the RTC later granted Interlink’s motion to declare the respondents in default, a decision they contested through an omnibus motion for reconsideration.
RTC Ruling
The RTC ruled in favor of Interlink, ordering the respondents to pay substantial damages based on the claims put forth. The RTC’s judgment was subsequently challenged by the respondents through a petition for certiorari to the Court of Appeals (CA) on jurisdictional grounds.
Court of Appeals Ruling
The CA reversed the RTC decision, concluding that the second service of summons was still defective and did not confer jurisdiction over the respondents. They instructed the RTC to ensure a valid service of summons in compliance with the Rules of Court.
Legal Principles on Jurisdiction
Jurisdiction over a defendant in civil cases is contingent upon valid service of summons or voluntary appearance. Without proper service, any judgment rendered is deemed void. In this instance, the CA delineated that personal service is required for domestically organized juridical entities only upon specific corporate officers, and the service upon Ochotorina did not satisfy these requirements.
Failure of Personal Service
The CA noted that the sheriff's attempt at personal service was insufficient as it only constituted one attempt. There was an established requirement for the sheriff to demonstrate the impossibility of personal service through multiple attempts before resorting to substituted service, which was not performed in this case.
Respondents' Special Appearance and Jurisdiction
The respondents entered a special appearance to contest the court&#
...continue readingCase Syllabus (G.R. No. 203298)
Background of the Case
- Petitioners, Interlink Movie Houses, Inc. and Edmer Y. Lim, filed a petition for review on certiorari against the Court of Appeals (CA) and respondents, Stationery Expressions Shop, Inc. and Josephine Lim Bon Huan.
- The case centers on a dispute regarding the service of summons and the jurisdiction of the Regional Trial Court (RTC) over the respondents.
- The RTC in Pasig City ruled in favor of Interlink, ordering the respondents to pay for unpaid rentals and damages.
- The CA later annulled the RTC decision, leading to the petition before the Supreme Court.
Factual Background
- On July 22, 2008, Interlink, through its president Edmer Y. Lim, filed a complaint for sum of money and damages due to unpaid rentals against Expressions and Bon Huan.
- Summons was initially served to a representative of Expressions, Jonalyn Liwanan, who claimed to forward the documents to her superior.
- Respondents entered a special appearance contesting the validity of the summons service, claiming it was defective.
- The RTC denied Interlink's motion to declare respondents in default, ordering a re-service of summons.
- A second service was made on May 11, 2009, to Amee Ochotorina, who was not among the designated officers according to the Rules of Court.
RTC Ruling
- The RTC eventually ruled in favor of Interlink, finding suff