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People's General Insurance Corporation vs. Guansing

PEOPLE'S GENERAL INSURANCE CORPORATION, PETITIONER, VS. EDGARDO GUANSING AND EDUARDO LIZASO, RESPONDENTS.

G.R. No. 204759 | 2018-11-14

DECISION
 
LEONEN, J.:
 
As a general rule, personal service is the preferred mode of service of summons. Substituted service is the exception to this general rule. For the sheriff to avail of substituted service, there must be a detailed enumeration of the sheriff's actions showing that a defendant cannot be served despite diligent and reasonable efforts. These details are contained in the sheriff's return. Thus, the sheriff's return is entitled to a presumption of regularity. Courts may allow substituted service based on what the sheriff's return contains.[1]

Failure to serve summons means that the court did not...