GR 140081; (June, 2005) (Digest)

G.R. No. 140081; June 23, 2005
TYSON’S SUPER CONCRETE, INC., et al., petitioners, vs. COURT OF APPEALS, et al., respondents.

FACTS

Romana Dela Cruz, the registered owner of several parcels of land, entered into a 20-year lease contract with petitioner Tyson’s Super Concrete, Inc. in 1992. Due to internal corporate disputes, the Securities and Exchange Commission (SEC) created a Management Committee to take over Tyson’s management in April 1995. The Committee’s members included Francis Chua (corporate secretary and a representative of one stockholder bloc) and an appointed Chairman. In February 1996, Dela Cruz filed an ejectment case against Tyson’s for non-payment of rentals. After several attempts, the sheriff served the summons at the residence of spouses Elsa Hao Chua (Tyson’s Treasurer) and Francis Chua. Francis Chua, a member of the Management Committee, acknowledged receipt.
Tyson’s failed to answer, leading the Metropolitan Trial Court (MeTC) to render a default judgment against it. Tyson’s moved to vacate the judgment, arguing invalid service of summons because it was served on Francis Chua, who allegedly lacked authority as he was not the Committee Chairman. The MeTC denied the motion, ruling service was valid on a corporate officer. Tyson’s then filed a petition for certiorari with the Regional Trial Court (RTC), which was dismissed. The Court of Appeals initially granted Tyson’s petition but later reversed itself in an Amended Decision, upholding the validity of the summons service.

ISSUE

Whether the Metropolitan Trial Court validly acquired jurisdiction over petitioner Tyson’s Super Concrete, Inc. through the service of summons on Francis Chua, a member of the SEC-created Management Committee.

RULING

Yes, the MeTC validly acquired jurisdiction. The Supreme Court affirmed the Court of Appeals’ Amended Decision, holding that service of summons upon Francis Chua was effective and binding upon the corporation. The legal logic rests on the application of the Rules of Court concerning service upon a private corporation. Under the rules, summons may be served on an officer or an agent authorized by appointment or by law to receive court processes. Francis Chua, as the corporate secretary of Tyson’s and a duly appointed member of the Management Committee tasked with managing the corporation, qualified as such an agent.
The Court rejected the argument that only the Committee Chairman could receive summons. Nothing in Presidential Decree No. 902-A or the SEC order creating the Committee stipulated such a limitation. The Court emphasized that even if the Committee had adopted an internal rule restricting authority to receive summons to its Chairman, such a rule cannot amend or supersede the Supreme Court-promulgated Rules of Court, which allow service on corporate officers. Since the Management Committee effectively stood in place of the corporate management, service on its member, Francis Chua, who was a corporate officer, constituted valid service on the corporation itself. Consequently, the MeTC’s acquisition of jurisdiction was proper, and its judgment stands.