Facts:

In the case of Lagrimas v. Abalos and Josefina A. Pangan, we note that the petitioners, spouses Jose R. Abalos and Lagrimas V. Abalos, initiated a complaint for recovery of possession of property and damages on July 22, 1983, against the private respondents Pepito Laculob, Nicolas Lacurum, Mateo Respicio, Luis de la Cruz, Benjamin Maracha, Federico Miones, and Onofre Fujiwara, Jr. The subject property, designated as Lot 12, Block 122-D, was located in Quezon City and measured approximately 408 square meters. The property was registered under Transfer Certificate of Title (TCT) No. 287646, issued by the Register of Deeds of Quezon City in favor of the Abalos spouses. Following the trial, on May 20, 1986, the Regional Trial Court ruled in favor of the Abalos, recognizing them as the lawful owners of the property and ordering private respondents to vacate the premises within sixty days of the judgment's finality. Additionally, the court mandated a monthly payment of P250.00 by

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Facts:

Background of the Case

• A complaint for recovery of possession of property and damages was filed on July 22, 1983, in the Regional Trial Court of Quezon City by the petitioners, Jose R. Abalos and Lagrimas V. Abalos (with Josefina A. Pangan as heir of the late Jose R. Abalos).
• The disputed property was described as Lot 12, Block 122-D, situated in Quezon City, with an area of about 408 square meters, and registered in the name of the petitioners under Transfer Certificate of Title (TCT) No. 287646.

Proceedings in the Trial Court

• After the issues were joined, the trial court conducted the trial on the merits of the case.
• On May 20, 1986, the trial court rendered a decision on the merits which:

- Adjudged the petitioners as the true and lawful registered owners of the subject property. - Ordered the intervenors, including defendants Federico Miones, Onofre Fujiwara, Jr., Mateo Respicio, Luis de la Cruz, Benjamin Maracha, and others claiming under them, to vacate the premises and remove any houses within sixty (60) days from the finality of the decision. - Imposed a monthly penalty of P250.00 for each month of continued occupancy if the vacating order was not observed.

Issues Raised on Appeal

• Private respondents (defendants and intervenors) appealed the trial court’s decision before the Court of Appeals.
• The primary grounds raised in their appeal were:

- The trial court erred by not dismissing the case for non-compliance with the conciliation process mandated under Section 6 of Presidential Decree (P.D.) No. 1508 – known as the Katarungan Pangbarangay Law. - The trial court erred in ordering the eviction of the respondents, allegedly in violation of Section 2 of P.D. No. 2016. - Even assuming the eviction order was legally sound, the trial court erred by ordering such eviction without a proper survey by a duly licensed surveyor to determine the exact location of the houses relative to the property. - The petitioners initially indicated their residence as being in Quezon City but later, with the court’s permission, corrected it to Caloocan City. - The private respondents did not object to the change of address and actively participated in the trial on the merits.

Developments in the Appellate Court

• On February 26, 1990, the Court of Appeals set aside the trial court’s judgment and dismissed the complaint and counterclaims with costs against the petitioners.
• A motion for reconsideration by the petitioners was filed and subsequently denied on July 6, 1990.

Relief Sought and Supreme Court’s Intervention

• The petition for review centered on the contention that the Court of Appeals erred in dismissing the complaint on the ground of non-compliance with the pre-litigation conciliation requirement under P.D. No. 1508, thus preventing a determination of the merits.
• The Supreme Court found that the conciliation requirement was inapplicable since:

- The petitioners and the private respondents resided in different localities (Caloocan City and Quezon City, respectively). - By not objecting to the petitioners’ address correction and by participating fully in the trial, the private respondents effectively waived their right to invoke the conciliation process.

Issue:

• Whether the trial court erred in not dismissing the case for the alleged failure to comply with the compulsory conciliation process provided under Section 6 of P.D. No. 1508 (the Katarungan Pangbarangay Law).
• Whether the trial court erred in ordering the eviction of the defendants-appellants and intervenors-appellants, purportedly in violation of Section 2 of P.D. No. 2016, which governs the scope of matters appropriate for barangay-level dispute resolution.
• Whether, even if the decision ordering eviction was presumed not to be violative of law, the trial court erred by failing to commission a survey by a duly licensed surveyor to ascertain the precise location of the structures relative to the property in question.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)