FACTS:
The petitioner, The Philippine American Life & General Insurance Company, filed a petition for review with the Court of Appeals (CA) after the CA dismissed its special civil action for certiorari and prohibition. The petitioner, a domestic corporation with its main office in Manila and a regional office in Davao City, was sued by respondent Milagros P. Morales for damages and reimbursement of insurance premiums. The complaint indicated that the petitioner could be served with summons and court processes through its manager at its Davao City branch office. The summons, along with the complaint, was served on the petitioner's Davao regional office in November 1999. The petitioner then filed a motion to dismiss the complaint, arguing that there was improper service of summons and, therefore, lacked jurisdiction. In response, the respondent filed an amended complaint, stating that summons and other court processes could also be served at the petitioner's principal office in Manila. The RTC denied the petitioner's motion to dismiss and ordered the issuance of an alias summons to be served at its main office in Manila. The petitioner filed a motion for reconsideration, which was also denied by the RTC. The petitioner then resorted to a special action for certiorari and prohibition with the CA, but the petition was dismissed, and the orders of the RTC were affirmed. Consequently, the petitioner filed this petition for review.
ISSUES:
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Whether the service of summons on the petitioner's regional office was improper.
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Whether the trial court acquired jurisdiction over the petitioner upon the service of alias summons on the amended complaint.
RULING:
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The Court held that the service of summons on the petitioner's regional office was proper. The Court ruled that under Sec. 11, Rule 14 of the 1997 Revised Rules of Civil Procedure, valid service of summons on a corporation can be made on the manager or a person in charge of the office or branch. Since the petitioner's manager was not available, the service of summons on the Insurance Service Officer at the regional office was considered acceptable.
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The Court also held that the trial court acquired jurisdiction over the petitioner upon the service of alias summons on the amended complaint. The Court cited Sec. 5, Rule 14 of the 1997 Revised Rules of Civil Procedure, which allows for the issuance of an alias summons when the previous summons was lost or unserved. The Court emphasized that the purpose of an alias summons is to provide an additional opportunity for the defendant to appear and defend the case, and any procedural defect in its issuance does not warrant the dismissal of the case.
PRINCIPLES:
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Valid service of summons on a corporation can be made on the manager or a person in charge of the office or branch.
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An alias summons may be issued when the previous summons was lost or unserved, with the purpose of providing an additional opportunity for the defendant to appear and defend the case. Any procedural defect in its issuance does not warrant the dismissal of the case.