REMEDIAL LAW | Villarama vs. Guno G.R. No. 197514, August 06, 2018

Villarama vs. Guno 

G.R. No. 197514, August 06, 2018


FACTS The case involves the sale of a property from spouses Marcial and Rita Reyes (Sps. Reyes) to spouses Crisantomas and Carmelita Yadao Guno (Sps. Guno). The Sps. Reyes executed a deed of absolute sale and later created a Trust Agreement with Prudential Bank (Prudential), naming their children as beneficiaries and eventually appointing Ramon Villarama as an irrevocable beneficiary. Sps. Guno later mortgaged the property to Prudential, leading to foreclosure due to non-payment. Prudential acquired the property at a public auction, resulting in TCT No. 355218 being issued in its name, which led to the eviction of Sps. Guno. Sps. Guno filed a complaint for annulment of the foreclosure sale against Prudential, which was upheld by the RTC and later affirmed by the Supreme Court. On July 17, 1997, Villarama filed a complaint against Sps. Guno for rescission of the promissory notes, deed of sale, and cancellation of title. The RTC issued an alias summons served on Carmelita, while Crisantomas was not served. The RTC declared Crisantomas in default. Villarama's complaint was granted, leading to the cancellation of titles and the award of damages. Crisantomas filed a motion to vacate the judgment, claiming improper service of summons, which the RTC denied, citing the binding nature of service on one spouse regarding community property. The CA reversed this, ruling that there was no valid service of summons. Whether the alias summons served on one spouse (Carmelita) is binding on the other spouse (Crisantomas) concerning community property and whether the service of summons was valid.


RULING YES. The Supreme Court reinstated the RTC's ruling, stating that the alias summons served on Carmelita was indeed binding on Crisantomas. The Court emphasized that proper service of summons is crucial for acquiring jurisdiction over a party, citing Manotoc vs. Court of Appeals: "The courts' jurisdiction over a defendant is founded on a valid service of summons.” 


The Supreme Court ruled that the RTC's initial decision was correct, as service on one spouse suffices for actions concerning community property, affirming the binding effect of such service.








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