GREEN STAR EXPRESS v. NISSIN-UNIVERSAL ROBINA CORPORATION

FACTS:

A vehicular accident occurred between a van owned by Universal Robina Corporation (URC) and a passenger bus owned by Green Star Express, Inc. (Green Star), resulting in the death of the van's driver. The bus driver, Fruto Sayson Jr., was charged with reckless imprudence resulting in homicide. Green Star sent a demand letter to Nissin-Universal Robina Corporation (NURC) for the repair of their bus, but NURC denied any liability and argued that the criminal case would determine the liabilities of the parties. The criminal case was later dismissed due to lack of evidence. Sayson and Green Star then filed a complaint for damages against NURC. NURC filed a Motion to Dismiss, claiming lack of jurisdiction due to improper service of summons. The Regional Trial Court (RTC) denied the motion, but the Court of Appeals (CA) reversed the RTC ruling and nullified its resolution, dismissing the complaint for lack of jurisdiction. Green Star and Sayson filed a petition for review before the Supreme Court.

ISSUES:

  1. Whether or not the summons was properly served on NURC, vesting the trial court with jurisdiction.

RULING:

  1. The Supreme Court ruled that the petition is without merit. It reiterated that the rules on service of summons for domestic private juridical entities must be strictly complied with for the court to acquire jurisdiction over the defendant. NURC argued that the summons should have been served on its officers in accordance with Section 11, Rule 14 of the Rules of Court. The court held that the revision in the rule limited the persons upon whom service of summons can be made, and service must only be made on the persons expressly listed in the rules. In this case, the summons was received by NURC's cost accountant, who is not one of the designated persons under Section 11. Therefore, the trial court did not validly acquire jurisdiction over NURC, even if the corporation actually received the summons. The court emphasized that notice, enabling the other party to present their defense, is essential to due process. Disregarding the rules on service of summons would result in depriving corporations of their right to present their defense. The Supreme Court affirmed the decision of the CA, dismissing the complaint for lack of jurisdiction.