Service of summons upon a corporation (1964 Rules)

Rule 14, Section 13 of the 1964 Rules of Court, which was then in force, allowed the service of summons upon a director of a private domestic corporation:

Sec. 13. Service upon private domestic corporation or partnership. - If the defendant is a corporation organized under the laws of the Philippines or a partnership duly registered, service may be made on the president, manager, secretary, cashier, agent, or any of its directors.

The aforementioned rule does not require that service on the private domestic corporation be served at its principal office in order for the court to acquire jurisdiction over the same. The Court, in Talsan Enterprises, Inc. vs. Baliwag Transit, Inc.,[1] citing Baltazar v. Court ofAppeals,[2] affirmed that:

[S]ervice on respondent's bus terminal at the address stated in the summons and not in its main office in Baliwag do not render the service of summons invalid. In Artemio Baltazar v. Court of Appeals, we held:

"The regular mode, in other words, of serving summons upon a private Philippine Corporation is by personal service upon one of the officers of such corporation identified in Section 13. Ordinarily, such personal service may be expected to be made at the principal office of the corporation. Section 13, does not, however, impose such requirement, and so personal service upon the corporation may be effected through service upon, for instance, the president of the corporation at his office or residential address." x x x.

In fine, the service of summons upon respondent Baliwag Transit is proper. Consequently, the trial court validly acquired jurisdiction over respondent Baliwag. (Citation omitted.)

[1]  369 Phil. 409, 419-420 (1999).

[2] 250 Phil. 349, 360-361 (1988).