Case Digest (G.R. No. 263014) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jose Audie Abagatnan et al. v. Spouses Jonathan and Elsa Clarito (G.R. No. 211966, August 7, 2017), petitioners Jose Audie Abagatnan, Josephine A. Parce, Jimmy Abagatnan, John Abagatnan, Jenalyn A. De Leon, Joey Abagatnan, Jojie Abagatnan, and Joy Abagatnan (children and successors of Lydia Capote) sought to eject respondents Jonathan and Elsa Clarito from a 480-sqm portion of Lot 1472-B in Barangay Cogon, Roxas City. Lot 1472-B was acquired by petitioners’ parents by Deed of Absolute Sale on August 1, 1967; Lydia died on October 4, 1999, and her conjugal share passed to her children. In 1990, respondents, distant relatives, were permitted to build a light-materials house on a portion of the lot, subject to vacating upon owners’ need. In September 2006, petitioners decided to sell the land; respondents declined the offer. A Demand Letter dated October 2, 2006 required respondents to vacate within 15 days, but they refused. On November 10, 2006, petitioners filed a Complaint f... Case Digest (G.R. No. 263014) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Acquisition and Succession
- On August 1, 1967, Wenceslao Abagatnan and his wife Lydia Capote purchased Lot 1472-B (5,046 sqm) in Brgy. Cogon, Roxas City, by Deed of Absolute Sale from Mateo Ambrad and Soteraña Clarito.
- Lydia died on October 4, 1999, and her children (co-petitioners) inherited her conjugal share in the property.
- Occupation by Respondents
- In 1990, respondents Jonathan and Elsa Clarito, distant relatives of Wenceslao, obtained permission to construct a light-materials house on a 480-sqm portion of Lot 1472-B, with the condition they vacate if required by the owner.
- In September 2006, petitioners decided to sell portions of Lot 1472-B (including the 480-sqm portion); they offered it to respondents, who declined to buy.
- Demand and Filing of Complaint
- On October 2, 2006, petitioners served a Demand Letter requiring respondents to vacate within 15 days; respondents refused to comply.
- On November 10, 2006, petitioners filed a Complaint for Unlawful Detainer and Damages in MTCC Branch 2, Roxas City, alleging barangay conciliation was not required since two petitioners resided outside Roxas City.
- Lower Courts’ Decisions
- MTCC (Aug. 17, 2007) ruled for petitioners: ordered respondents to remove structures, pay P500/month occupancy from date of filing, and costs.
- RTC (Jan. 15, 2008) denied respondents’ appeal: found petitioners’ proof of ownership preponderant and held that the conciliation issue was waived for not being raised in the pre-trial order.
- Court of Appeals Proceedings
- CA (June 20, 2013) affirmed the factual findings but dismissed the Complaint without prejudice for failure to secure prior barangay conciliation under Sec. 412, LGC.
- CA Resolution (Feb. 3, 2014) denied petitioners’ motion for reconsideration; petitioners then filed a Rule 45 petition before the Supreme Court.
Issues:
- Whether the CA correctly dismissed the Complaint for failure to comply with the mandatory barangay conciliation requirement under Section 412 of the Local Government Code, despite some real parties in interest residing outside the same city or municipality.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)