Title
Agbayani vs. Belen
Case
G.R. No. L-65629
Decision Date
Nov 24, 1986
Petitioners sought quieting of title over land in Sual, Pangasinan; SC ruled Barangay Lupon lacked jurisdiction as parties resided in non-adjoining cities, exempting them from conciliation under P.D. 1508.
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Case Digest (G.R. No. L-65629)

Facts:

  1. Parties Involved: Petitioners Teresita E. Agbayani and Lucas F. Agbayani filed a civil action against respondents Spouses Severo A. Villafuerte and Ana P. Villafuerte, seeking quieting of title and damages over three parcels of land in Barangay Tobuan, Sual, Pangasinan.
  2. Subject Matter: The dispute involved three parcels of land located in Barangay Tobuan, Sual, Pangasinan.
  3. Procedural Background: The petitioners filed a complaint in the Regional Trial Court (RTC). The respondents moved to dismiss the case, arguing that the petitioners failed to submit the dispute to the Barangay Lupon for conciliation as required under Presidential Decree (P.D.) No. 1508.
  4. Trial Court's Decision: The RTC granted the motion to dismiss, ruling that the dispute fell within the authority of the Barangay Lupon and that the petitioners should have first complied with the conciliation process under P.D. No. 1508 before filing the case in court.

Issue:

  1. Primary Issue: Whether the petitioners were required to submit their dispute to the Barangay Lupon for conciliation before filing their complaint in court, given that the parties resided in different cities or municipalities and the properties in question were located in the same barangay.
  2. Sub-Issue: Whether the Barangay Lupon had jurisdiction over the dispute, considering the residence of the parties and the location of the properties.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court annulled the RTC's dismissal order and remanded the case for further proceedings, holding that the petitioners were not required to submit their dispute to the Barangay Lupon for conciliation before filing their complaint in court.


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