G.R. No. L-16332, December 18, 1920
JULIAN OCAMPO, petitioner, vs. MAXIMINO MINA, Judge, and TOMAS AREJOLA, respondents.

FACTS:
Tomas Arejola filed an election protest against Julian Ocampo and others in the Court of First Instance of Ambos Camarines on June 27, 1919. Ocampo was declared elected provincial governor by the provincial board. Arejola attempted to notify Ocampo of the protest by sending a copy via registered mail, which was received on July 2, 1919, by Ramon Enrile Jr., Ocampo’s brother-in-law, who allegedly was authorized to receive his correspondence. Ocampo initially entered a special appearance on August 11, 1919, solely to challenge the court’s jurisdiction over his person. However, on February 12, 1920, Ocampo, through his lawyers, filed a general appearance, participated in the trial by cross-examining witnesses, objecting to evidence, presenting his own evidence, and filing an answer to the protest. Ocampo then petitioned for prohibition, arguing the trial court never acquired jurisdiction over him because the notification by publication was invalid. This Court initially granted the writ on September 23, 1920. Upon Arejola’s motion for reconsideration, the Court allowed his answer and set aside the initial decision for further proceedings.

ISSUE:
1. Whether notification of an election protest via registered mail, received by an authorized person, is valid to confer jurisdiction over the protestee.
2. Whether a general appearance and active participation in the protest proceedings by the protestee after the 20-day notification period confers jurisdiction upon the court.

RULING:
1. Yes, notification by registered mail is valid if proven effective. The Court held that notification of an election protest within the 20-day period by registered mail is valid, provided it is proven that the registered package contained a copy of the protest and the notice, and that it was received by the protestee personally or through a duly authorized representative. Citing Biagtan v. Llorente and Garcia, the Court found that Ocampo was duly notified, as the evidence showed the registered mail containing the protest was received by his authorized brother-in-law.
2. Yes, a general appearance confers jurisdiction. The Court, citing Flores v. Zurbito, ruled that a voluntary general appearance constitutes a waiver of any defect in the notification and submits the party to the court’s jurisdiction. Ocampo’s general appearance on February 12, 1920, coupled with his active participation in the trialcross-examining witnesses, filing motions, presenting evidence, and filing an answeramounted to a submission to the court’s jurisdiction. The law does not prescribe a period for such appearance; jurisdiction is vested by the timely filing of the protest, notification within 20 days, and the posting of a bond.
The Court vacated its prior decision granting the writ of prohibition and denied Ocampo’s petition, ordering the trial court to proceed with the election protest. Costs were imposed on the petitioner.