The Supreme Court held that when a husband and wife have shared conjugal interests in a legal matter, serving a summons to the wife can be considered binding for both spouses, even if the husband claims he was not personally served. This ruling clarifies that the protection of due process is upheld when one spouse actively participates in the proceedings, especially when the obligations stem from conjugal property. The decision underscores that unsubstantiated denials of summons receipt will not automatically invalidate court proceedings, ensuring efficiency in resolving long-standing legal disputes.

Shared Debts, Shared Notices: Can Serving One Spouse Bind a Marriage?

This case revolves around a complaint filed by Ramon R. Villarama against spouses Crisantomas and Carmelita Guno, seeking the rescission of promissory notes, a deed of sale, and the cancellation of a title. The central issue is whether Crisantomas Guno was validly served with summons in Civil Case No. Q-97-31700, despite his claim of not receiving it. This question is crucial because valid service of summons is a prerequisite for a court to acquire jurisdiction over a defendant’s person, ensuring their right to due process. Without proper service, a court’s decision may be deemed void.

The Supreme Court addressed the matter of service of summons, particularly in the context of marital obligations. The court recognized that when obligations are incurred during a marriage and involve conjugal property, both spouses are considered co-defendants with shared interests. In the case of Manotoc vs. Court of Appeals, the Supreme Court emphasized the importance of proper service of summons, stating:

The courts’ jurisdiction over a defendant is founded on a valid service of summons. Without a valid service, the court cannot acquire jurisdiction over the defendant, unless the defendant voluntarily submits to it. The defendant must be properly apprised of a pending action against him and assured of the opportunity to present his defenses to the suit. Proper service of summons is used to protect one’s right to due process.

Building on this principle, the court examined whether the service of summons upon Carmelita Guno could be deemed binding on her husband, Crisantomas. The court noted that the alias summons was served at the U.P. Law Center, Diliman, Quezon City, an address associated with both spouses. While Carmelita acknowledged receipt, Crisantomas claimed he never received the summons. The court found Crisantomas’s denial to be unsubstantiated, as he provided no additional evidence to support his claim that he was not notified of the proceedings or the decision of the case. In fact, he did not even assert that he and Carmelita were separated at the time, a claim made only later in his motion.

Adding to the complexity, Carmelita actively participated in the proceedings, filing an answer and raising arguments related to a previous case involving the same documents. This participation indicated that the interests of both spouses were being represented. Therefore, the court had to consider whether Carmelita’s actions could be construed as representing the conjugal partnership, given that the obligations in question arose during their marriage. The court noted that the couple was married before the effectivity of the Family Code, and absent any marriage settlement, their property relations were governed by the regime of conjugal partnership of gains, where all property acquired during the marriage is presumed conjugal.

The Supreme Court referenced Article 161(1) of the New Civil Code (now Article 121 [2 and 3] of the Family Code of the Philippines), which provides that the conjugal partnership is liable for debts and obligations contracted by either spouse for the benefit of the partnership. Given that the deed of sale and promissory notes were executed during the marriage, the court reasoned that the obligations were subsumed under the conjugal partnership. Therefore, the spouses were correctly made co-defendants because they shared the same interests in the matter.

The court also considered whether the action brought by Villarama was an action in personam, which is an action against a person based on their personal liability. As the case involved the rescission of promissory notes, a deed of sale, and the cancellation of title related to documents entered into by both spouses, the court determined it was indeed an action in personam. Consequently, the court reiterated that Carmelita’s receipt of the summons was binding not only on her but also on Crisantomas.

The Supreme Court underscored that the essence of service of summons is to protect the right to due process. In this case, Crisantomas failed to adequately prove that he did not receive the summons or that he was unaware of the proceedings. Carmelita actively participated in the case, litigating their shared interests. Further, Crisantomas did not demonstrate that he and Carmelita were separated or that their marriage was annulled at the time. The court cited Montefalcon, et al. vs. Vasquez, where it stated:

x x x A plaintiff is merely required to know the defendant’s residence, office or regular business place. He need not know where a resident defendant actually is at the very moment of filing suit. He is not even duty-bound to ensure that the person upon whom service was actually made delivers the summons to the defendant or informs him about it. The law presumes that for him. It is immaterial that defendant does not receive actual notice.

The Supreme Court concluded that overturning the lower court’s decision would only prolong the litigation, as Villarama would be forced to file a new case against Crisantomas, who had no stronger defense than Carmelita. Therefore, given the circumstances, the alias summons served upon Carmelita was deemed binding on Crisantomas. The Court therefore did not see it as necessary to evaluate the validity of substituted service.

FAQs

What was the key issue in this case?	The central issue was whether Crisantomas Guno was validly served with a summons, given his claim of non-receipt, and whether serving his wife, Carmelita, was sufficient for the court to acquire jurisdiction over him.
Why was the service of summons on Carmelita considered important?	Carmelita’s receipt of the summons was significant because the case involved conjugal property and obligations, where both spouses shared interests. Her active participation in the proceedings also implied that the interests of both spouses were being represented.
What is an action in personam?	An action in personam is a legal action directed against a specific person based on their personal liability. In this case, it involved the rescission of contracts and cancellation of title related to documents signed by both Crisantomas and Carmelita.
What is the conjugal partnership of gains?	The conjugal partnership of gains is a property regime where all property acquired during the marriage through onerous title (valuable consideration) is owned jointly by the spouses. Debts and obligations incurred for the benefit of the partnership are also the responsibility of both spouses.
What did Crisantomas Guno argue in his defense?	Crisantomas argued that he was never served with the summons and was unaware of the proceedings against him. He claimed that he and Carmelita were separated, and therefore, service on her should not be considered as service on him.
Why did the Supreme Court reject Crisantomas Guno’s argument?	The Supreme Court rejected his argument because he failed to provide sufficient evidence to support his claims, such as proof of separation or annulment. Additionally, his wife Carmelita actively participated in the case, representing what the court deemed to be their conjugal interests.
What does the ruling imply for married couples in legal proceedings?	The ruling suggests that in cases involving conjugal property or shared obligations, service of summons on one spouse may be deemed sufficient for both, especially when the other spouse actively participates in the proceedings. It underscores the importance of due process and ensures efficient resolution of cases.
What was the effect of Carmelita’s active participation in the case?	Carmelita’s active participation showed that the conjugal partnership and its interests were being represented in court. This led the court to believe that due process was observed, even if Crisantomas claimed non-receipt of the summons.
How did the court use precedent to support its decision?	The Court cited the case of Montefalcon, et al. vs. Vasquez, 577 Phil. 383 (2008). The court also referenced Article 161(1) of the New Civil Code to determine if the case warranted the service of summons to only one spouse.

This case reinforces the principle that when spouses share conjugal interests, notice to one can, in certain circumstances, serve as notice to both, preventing parties from using technicalities to evade legal responsibilities. The decision emphasizes the need for factual substantiation of claims and active participation in legal proceedings to protect one’s rights.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: VILLARAMA VS. GUNO, G.R. No. 197514, August 06, 2018