GR 149625; (September 2007) (Digest)
G.R. No. 149625 ; September 28, 2007
WEENA EXPRESS, INC., Petitioner, vs. GODOFREDO R. RAPACON and RENE GUCON, Respondents.
FACTS
A vehicular accident occurred on March 14, 1995, involving a bus owned by petitioner Weena Express, Inc. and a cargo truck owned by respondent Godofredo Rapacon and driven by respondent Rene Gucon. The accident resulted in a death, injuries, and property damage. Respondents filed a Complaint for Damages against petitioner. Summons and the complaint were served on August 4, 1995, upon Rolando Devera, a claim employee of petitioner, who voluntarily received them. Petitioner failed to file an answer, leading the Regional Trial Court (RTC) to declare it in default and render a judgment awarding damages to respondents based on ex-parte evidence.
Petitioner moved to lift the order of default, arguing it failed to receive the summons due to the simple negligence of Devera, whom it claimed was not a proper agent for service. The RTC refused. On appeal, the Court of Appeals (CA) affirmed the RTC’s jurisdiction over petitioner, finding service of summons upon Devera valid, but modified the award by deleting compensation for loss of income. Petitioner sought review, contending the trial court never acquired jurisdiction due to improper service.
ISSUE
Whether the Court of Appeals erred in ruling that the trial court acquired jurisdiction over petitioner through the service of summons upon its claim employee, Rolando Devera.
RULING
The Supreme Court denied the petition, upholding the CA’s ruling. The procedural rule applicable at the time was Section 13, Rule 14 of the 1964 Rules of Court, which allowed service of summons upon a corporation’s “agent.” The Court, citing Villa Rey Transit, Inc. v. Far East Motor Corporation, defined an “agent” in this context as a representative so integrated with the corporation that it is reasonable to presume he would realize his responsibilities and know what to do with legal papers served on him. The evidence established that Devera, as a claim employee, was precisely tasked with following up cases for and against the corporation. His role was vital and representative in relation to the corporation’s legal matters, making him an “agent” authorized to receive court processes. Petitioner’s own motion to lift the default order admitted Devera’s role in handling its cases. Therefore, service upon Devera was proper and binding, effectively vesting the RTC with jurisdiction over petitioner. The CA committed no reversible error.