Facts:
The case initiated following a vehicular accident on February 25, 2003, involving a Mitsubishi L-300 van owned by Universal Robina Corporation (URC) and a passenger bus of Green Star Express, Inc. (Green Star), leading to the death of the van’s driver. Subsequently, the bus driver, Fruto Sayson, Jr., faced charges for reckless imprudence resulting in homicide. Green Star demanded reparations from the respondent, Nissin-Universal Robina Corporation (NURC), for the bus repairs, amounting to P567,070.68. NURC denied liability, citing the pending criminal case to determine the parties’ liabilities. The criminal case was dismissed on grounds of insufficient evidence.
Green Star and Sayson filed a damages suit against NURC before the Regional Trial Court (RTC) of San Pedro, Laguna. Despite being served, NURC filed a Motion to Dismiss based on improper service as the summons was received by their cost accountant, Francis Tinio, which led to disputes over jurisdiction. The RTC denied the motion, asserting that there was actual receipt of the summons, ensuring compliance. Dissatisfied, NURC sought certiorari from the Court of Appeals (CA), which eventually led to the RTC’s resolutions being nullified due to lack of jurisdiction, prompting Green Star and Sayson to elevate the issue to the Supreme Court (SC).
Issues:
1. Whether the service of summons on NURC was properly executed.
Court’s Decision:
The SC deemed the petition meritless, strictly adhering to rules concerning the service of summons for domestic private juridical entities. It highlighted the changed rules that specify who in a corporation can receive summons, narrowing it down to the president, managing partner, general manager, corporate secretary, treasurer, or in-house counsel exclusively. Since the service was made to a cost accountant, the SC concluded that jurisdiction over NURC was invalid despite actual receipt. The decision underscored the importance of due process, which requires correct service of summons as a vital component.
Doctrine:
The doctrine established revolves around the strict compliance required in the service of summons to a domestic private juridical entity. Summons must be served exclusively to the persons listed under Section 11, Rule 14 of the 1997 Rules of Court. This adherence ensures the due process and right to defense of corporations in litigation, emphasizing the non-negotiable nature of procedural rules in judicial processes.
Class Notes:
– Service of Summons: Must strictly comply with the enumeration under Section 11, Rule 14 of the 1997 Rules of Court when dealing with domestic private juridical entities.
– Due Process: The proper service of summons is essential for due process, enabling the defendant to be heard and present evidence.
– Strict Adherence to Rules: The SC emphasizes the importance of following the letter of procedural rules to ensure fair and orderly administration of justice.
Historical Background:
The alteration from the old to the new rules on service of summons reflects the judiciary’s intention to refine procedural aspects ensuring clarity and specificity in legal proceedings. Previously, service upon any representative considered as an “agent” was deemed sufficient. This change underscores a more stringent approach to ensuring that legal notices reach the appropriate parties within a corporation, emphasizing the safeguarding of due process and the systematic administration of justice.
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