Uy v. Del Castillo

In 1996 Crispulo Del Castillo sued Jaime Uy and his wife Conchita for quieting of title and reconveyance of Lot 791 before the RTC of Mandaue City. Because Jaime had died in 1990, the complaint was amended to implead his children, the Uy siblings. The RTC ruled for Crispulo's heirs (who substituted him on his death), nullified the titles, and ordered petitioners to pay moral damages and litigation costs of P20,000.00 each and attorney's fees of 25% of the zonal value of Lot 791. The ruling became final after appeals to the CA and the Supreme Court. On execution, a notice of garnishment sought P13,788,250.00 in attorney's fees. Petitioners moved to quash the writ, later claiming the siblings were never served summons. The RTC nullified the garnishment, re-computed the fees at P3,387,970.00 using the 1996 zonal value, but denied the motion to quash. The CA affirmed, noting that the siblings' counsel had manifested that they received the summons. Petitioners also argued that respondents should have proceeded against Jaime's estate under Section 20, Rule 3.

1. 1Whether the RTC acquired jurisdiction over the persons of the Uy siblings despite their claim that they were never served summons.
2. 2Whether the Uy siblings could be held liable for the monetary awards, or whether respondents should have proceeded against Jaime's estate under Section 20, Rule 3 of the Rules of Court.

The petition was partly granted. On jurisdiction, petitioners' counsel had stated in a Manifestation/Motion that they "received the Summons with a copy of the Second Amended Complaint"; this was a judicial admission, conclusive absent palpable mistake. Even assuming no summons, they voluntarily submitted to the RTC's jurisdiction by filing an answer and actively participating: sibling Ericson testified for the defense and they appealed to the Supreme Court. Active participation "is tantamount to an invocation of the court's jurisdiction and a willingness to abide by the resolution of the case," barring a later challenge; jurisdiction over a defendant is acquired by valid service of summons or voluntary submission. Their denial of counsel's authority was an afterthought. On liability, since Jaime died before the suit was filed, the rules on substitution (Section 16, Rule 3) and Section 20, Rule 3 on contractual money claims did not apply; the siblings were impleaded in their personal capacities. Still, the Court relaxed the doctrine of immutability of judgment: as successors-heirs to Jaime's interest in Lot 791, the siblings "cannot be personally bound to respond to the decedent's obligations beyond their distributive shares," a compelling circumstance, and respondents would not be prejudiced because Conchita remained liable. The CA rulings were affirmed with modification, limiting the siblings' monetary liability to the total value of their inheritance from Jaime Uy.