DuBois Regional v. Folgueras, A.

Superior Court of Pennsylvania·Decided September 3, 2026·No. 1438 WDA 2025·Unpublished·Bender

Opinion

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

DUBOIS REGIONAL MEDICAL CENTER : IN THE SUPERIOR COURT OF T/D/B/A PENN HIGHLANDS DUBOIS : PENNSYLVANIA :

:

v. :

:

:

ANNETTE FOLGUERAS, M.D. :

: No. 1438 WDA 2025

Appellant :

Appeal from the Order Entered October 13, 2025 In the Court of Common Pleas of Clearfield County Civil Division at No: 2022-510-CD

BEFORE: McLAUGHLIN, J., KING, J., and BENDER, P.J.E. MEMORANDUM BY BENDER, P.J.E.: FILED: SEPTEMBER 3, 2026 Annette Folgueras, M.D. (Appellant) appeals from the order denying her petition to open default judgment in this civil matter initiated by Dubois Regional Medical Center, t/d/b/a Penn Highlands Dubois (Appellee), for the return of an overpayment of severance pay. Upon review, we affirm.

The trial court summarized the pertinent history as follows:

The Parties entered into a written Physician Employment Agreement on September 24, 2020. Pursuant to that Agreement, [Appellant] commenced work as an anesthesiologist [with Appellee] on October 1, 2020. [Appellee] exercised its right to terminate its Agreement with [Appellant] without cause by letter dated April 15, 2021.

[Appellant] was entitled to 90 days severance pay following this termination of her employment. Unfortunately, [Appellee]

overpaid. This mistake was caused by a clerical/processing error in its payment department. [Appellee] made repeated demand to [Appellant] for reimbursement. She failed to pay. [Appellee] filed a Complaint on April 25, 2022 to recover these overpayments

together with the balance due on a loan it made to [Appellant].

[Appellant] did not respond to the Complaint. [Appellee’s] counsel sent [Appellant] the required 10 Day Notice pursuant to Pa.R.C.P.

237.1. [Appellant] still failed to file a response to the Complaint.

[Appellee’s] counsel then filed a Praecipe for Default Judgment.

Judgment was entered in favor of [Appellee] and against [Appellant] by the Clearfield County Prothonotary on July 5, 2022 in the amount of $214,770.52.

[Appellant] then did absolutely nothing in regard to this case for almost three years, until she filed a Petition to Open the Default Judgment for Lack of Personal Jurisdiction and Improper Service of Process on March 18, 2025. [Appellee] filed an Answer to [Appellant’s] Petition on April 8, 2025 and an Amended Answer on May 6, 2025. The [c]ourt held an evidentiary hearing on August 15, 2025 and at the conclusion of the same ordered briefs. By Order [entered October 13], 2025 the [c]ourt denied [Appellant’s]

Petition to Open Judgment.

Trial Court Opinion, 12/9/25, at 1-2.

This timely appeal followed. Both Appellant and the trial court complied with Pa.R.A.P. 1925.

Appellant presents the following issues for our review:

1. Whether the trial court committed legal error by holding that compliance with the “reasonably calculated to give actual notice”

clause in 42 Pa.C.S. § 5323(a) is sufficient for valid out-of-

Commonwealth service, thereby excusing strict compliance with one of the statute’s five enumerated methods and applying a lowered standard to substituted service under Pa.R.C.P. 402(a)(2)

and 404?

2. Whether the trial court erred as a matter of law and abused its discretion by denying the Petition to Open Default Judgment where substituted service on Murat Senelt was improper under Pa.R.C.P. 402(a)(2)(i), 404(1), and 42 Pa.C.S. § 5323(a), thereby depriving the court of personal jurisdiction and rendering the default judgment void ab initio?

3. In the alternative, whether the trial court abused its discretion by failing to apply the equitable three-prong test of Cintas Corp.

v. Lee’s Cleaning Servs., Inc., 700 A.2d 915 (Pa. 1997) and McCoy v. Public Acceptance Corp., 305 A.2d 698 (Pa. 1973)

with the required liberality, where Appellant demonstrated prompt filing upon discovery, a reasonable excuse for non-response based on lack of actual notice, and a meritorious defense of fraudulent inducement and equitable estoppel?

Appellant’s Brief at 4-5.

“Initially, we recognize that trial courts can apply legal or equitable principles in reviewing petitions to strike or open default judgments.” Wells Fargo Bank, N.A. v. Vanmeter, 67 A.3d 14, 16-17 (Pa. Super 2013). “Since [petitions to open default judgments] relate to the trial court’s exercise of its equitable powers, we will not disturb the trial court’s denial of [a petition to open] absent a misapplication of the law or a clear abuse of discretion by the trial court.” Id. at 17. “An abuse of discretion occurs when a trial court, in reaching its conclusions, overrides or misapplies the law, or exercises judgment which is manifestly unreasonable, or the result of partiality, prejudice, bias or ill will.” Jacks Auto Parts Sales, Inc. v. MJ Auto Body and Repair LLC, 305 A.3d 162, 166 (Pa. Super. 2023) (citation omitted). “Further, the party petitioning to open a judgment bears the burden of establishing such relief.” Id. at 167.

In her first two issues, Appellant argues that the trial court should have granted her petition to open the default judgment because the court lacked personal jurisdiction since she was deprived of appropriate service. Appellant asserts that she was not personally served with notice of Appellee’s complaint and that substitute service was not effective because it did not satisfy the requirements under our rules of civil procedure. Specifically, she alleges she

did not receive service of the civil complaint because service was made upon Mr. Murat Senelt as he was exiting Appellant’s residence. Appellant maintains that Mr. Senelt was not “a person in charge” and qualified to receive service. Rather, Appellant contends “Mr. Senelt was hired solely for menial tasks – feeding cats, watering plants, and checking appliances – with no broader authority over the residence or any managerial discretion. He had no keys (only garage access via code), did not reside there, and was not responsible for property decisions.” See Appellant’s Brief at 24. We disagree.

A court must have personal jurisdiction over a party to enter a judgment against it. [A]ction taken by a court without jurisdiction is a nullity. Because jurisdiction over a person is dependent upon proper service, the Pennsylvania Supreme Court has held that the rules relating to service of process must be strictly followed.

Dubrey v. Izaguirre, 685 A.2d 1391, 1393 (Pa. Super. 1996) (citing Sharp v. Valley Forge Med. Ctr. & Heart Hosp., Inc., 221 A.2d 185, 187 (Pa. 1966)). “In the absence of valid service, a court lacks personal jurisdiction over a party and is powerless to enter judgment against him.” U.K. LaSalle, Inc. v. Lawless, 618 A.2d 447 (Pa. Super. 1992). Therefore, “where the party seeking to open a judgment asserts that service was improper, a court must address this issue first before considering any other factors.” Digital Commc’ns Warehouse, Inc. v. Allen Invs., LLC, 223 A.3d 278, 288 (Pa. Super. 2019). “When determining a petition to open a judgment, matters dehors the record filed by the party in whose favor the warrant is given, i.e., testimony, depositions, admissions, and other evidence, may be considered

by the court.” Resolution Trust Corp. v. Copley Qu-Wayne Associates, 683 A.2d 269, 273 (Pa. 1996) (citation omitted).

Pennsylvania courts may exercise personal jurisdiction over non-

resident defendants under the Pennsylvania long-arm statute. Relevant to this matter, the statute provides:

(a) General rule.--A tribunal of this Commonwealth may exercise personal jurisdiction over a person . . . who acts directly, or by an agent, as to a cause of action or another matter arising from such person:

(1) Transacting any business in this Commonwealth.

Without excluding other acts which may constitute transacting business in this Commonwealth, any of the following shall constitute transacting business for purpose of this paragraph:

(i) The doing by any person in this Commonwealth of a series of similar acts for the purpose of thereby realizing pecuniary benefit or otherwise accomplishing an object.

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