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RAPID CITY REALTY v. ORLANDO VILLA

FACTS:

Rapid City Realty and Development Corporation (petitioner) filed a complaint for declaration of nullity of subdivision plans, mandamus, and damages against several defendants, including Spouses Orlando and Lourdes Villa (respondents). After failed attempts at personal service, the court process server resorted to substituted service by serving the summons upon respondents' househelp. Respondents failed to file an answer, and the trial court declared them in default. Respondents then filed a motion to lift the order of default, claiming that they only received the pertinent papers on a later date. The trial court set aside the order of default but respondents still did not file an answer, resulting in the trial court re-declaring them in default. Respondents filed an omnibus motion, this time claiming that the trial court did not acquire jurisdiction over their persons due to invalid service of summons. The trial court denied their motion and proceeded to receive ex-parte evidence for the petitioner's case. Respondents filed a certiorari petition before the Court of Appeals, which annulled the trial court's orders declaring respondents in default. The petitioner sought a review of the appellate court's decision before the Supreme Court.

ISSUES:

  1. Whether the trial court acquired jurisdiction over the respondents via the substituted service of summons.

  2. Whether the respondents' filing of a Motion to Lift Order of Default constituted a voluntary submission to the jurisdiction of the court.

RULING:

  1. The trial court did not acquire jurisdiction over the respondents due to invalid substituted service of summons. However, jurisdiction was acquired through respondents' voluntary appearance.

  2. The respondents' filing of a Motion to Lift Order of Default constituted voluntary submission to the court’s jurisdiction, as they did not specify that they were making a special appearance solely to contest jurisdiction.

PRINCIPLES:

  • Voluntary Appearance Under Section 20 of Rule 14 of the Rules of Court, a defendant's voluntary appearance in an action is equivalent to service of summons.

  • Special Appearance A special appearance solely to challenge the court’s jurisdiction does not amount to voluntary submission to the court’s jurisdiction.

  • Jurisdiction Over Person A court acquires jurisdiction over a defendant either by proper service of summons or by the defendant’s voluntary appearance that seeks affirmative relief without explicitly challenging jurisdiction.