Case Digest (G.R. No. L-65629)
Facts:
Teresita E. Agbayani and Lucas F. Agbayani v. The Honorable Antonio M. Belen and Spouses Severo A. Villafuerte and Ana P. Villafuerte, G.R. No. 65629, November 24, 1986, Supreme Court First Division, Narvasa, J., writing for the Court. Petitioners sought nullification of the Regional Trial Court's Order dated September 28, 1983 (Civil Case No. 15912), issued by Hon. Antonio M. Belen, Presiding Judge, Branch XXXVIII, First Judicial Region.Petitioners instituted a civil action for quieting of title and damages involving three parcels of land in Dayomaca (Tobuan), Poblacion, Sual, Pangasinan against private respondents the Spouses Severo A. Villafuerte and Ana P. Villafuerte (and other persons). Respondents moved to dismiss on the ground that the complaint was filed without first submitting the controversy to Barangay conciliation (the Lupon) as required by P.D. No. 1508.
The RTC granted the motion and dismissed the case for lack of jurisdiction to try it, reasoning that, although the parties resided in different barangays or municipalities, the properties were located in the same barangay (Barangay Tobuan) and therefore the dispute fell within the authority of the Lupon under Section 6 of P.D. No. 1508; accordingly, the RTC held that the precondition of conciliation had not been complied with and the case could not be filed in court.
The petitioners brought the matter to the Supreme Court seeking annulment of the RTC Order. The Supreme Court reviewed the trial court's dismissal and the application of P.D. No. 1508 to...(Pro-only)
Issues:
- Does the precondition of Barangay conciliation under P.D. No. 1508 apply when the parties actually reside in barangays of different cities or municipalities that do not adjoin, even though the real property in dispute is located in a single barangay?
- If non-compliance with the Lupon conciliation requirement is established, does such non-compliance deprive the trial court of jurisdiction and warrant dismissal, or is it a procedural defect ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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