G.R. No. 197514 . August 06, 2018.
RAMON R. VILLARAMA, PETITIONER, VS. CRISANTOMAS D. GUNO, HON. JUDGE RAMON A. CRUZ, PRESIDING JUDGE OF THE REGIONAL TRIAL COURT OF QUEZON CITY, BRANCH 223, CARMELITA YADAO GUNO AND PRUDENTIAL BANK AND TRUST COMPANY, RESPONDENTS.

FACTS

The case originated from a sale of property between the Sps. Reyes and the Sps. Crisantomas and Carmelita Guno. The Sps. Guno later mortgaged the property to Prudential Bank, which foreclosed on it. In a prior case, the foreclosure was annulled, and the Sps. Guno’s title was reinstated. Subsequently, petitioner Ramon Villarama, an irrevocable beneficiary under a trust agreement over the promissory notes from the original sale, filed a complaint for rescission of those notes and the deed of sale against the Sps. Guno. Summons was served at the U.P. Law Center address provided for Carmelita, who filed an answer. An alias summons for Crisantomas was served via substituted service at a Pasig City address on his sister. Crisantomas did not file an answer and was declared in default. The RTC rendered a decision granting rescission. After the decision became final, Crisantomas filed a Special Appearance with Motion to Vacate Judgment, arguing the judgment was void due to improper service of summons.

ISSUE

Whether the trial court acquired jurisdiction over the person of respondent Crisantomas Guno, thereby rendering the judgment valid and not void.

RULING

Yes, the trial court validly acquired jurisdiction. The Supreme Court ruled that the action for rescission of the promissory notes and deed of sale filed by Villarama was a suit that necessarily affected the conjugal partnership property of the Sps. Guno. Under the regime of absolute community of property, which governed their marriage, the husband and wife are joint administrators of the community property. Consequently, they must sue or be sued jointly. Service of summons upon one spouse is deemed service upon the other, as one spouse represents the conjugal partnership. Since Carmelita Guno was validly served with summons at the U.P. Law Center address—the very address provided by Villarama in his complaint where she could be served—and she entered her appearance by filing an answer, the court acquired jurisdiction over both spouses. The Court emphasized that the law presumes the served spouse will inform the other, and actual notice to Crisantomas is immaterial for jurisdiction. This principle prevents undue delay, especially since the merits of the rescission case had already been fully litigated with Carmelita’s participation. Therefore, Crisantomas’s motion to vacate the judgment was properly denied by the RTC, and the Court of Appeals’ decision nullifying that order was reversed.