Facts:

This case revolves around a legal conflict between Librada M. Aquino (Petitioner) and Ernesto S. Aure (Respondent) regarding a parcel of land situated in Roxas District, Quezon City, covering an area of 449 square meters, which is registered under Transfer Certificate of Title No. 205447 at the Registry of Deeds of Quezon City. The dispute arose from a complaint for ejectment filed by Aure and E.S. Aure Lending Investors, Inc. against Aquino on June 4, 1996, citing that they acquired the property from the spouses Aquino through a Deed of Sale. Aure alleged that despite receiving substantial consideration for the property, the spouses Aquino refused to vacate it. Aquino's defense was that the complaint lacked cause of action, asserting that the sale was governed by a Memorandum of Agreement (MOA) which stipulated that Aure was to secure a loan using the property as collateral, with proceeds due to the spouses, which they never received.

The Metropolitan Trial Court (MeTC) di

...

Facts:

Parties and Transaction Background

• Librada M. Aquino (Petitioner) and her husband were the registered owners of a parcel of land in Roxas District, Quezon City, with an area of 449 square meters covered by Transfer Certificate of Title (TCT) No. 205447.
• Respondent Ernest S. Aure, together with E.S. Aure Lending Investors, Inc. (collectively “Aure and Aure Lending”), purportedly acquired the subject property from the Aquino spouses via a Deed of Sale executed on 4 June 1996.
• In the sale transaction, it was alleged that after receiving substantial consideration, Aquino and her husband refused to vacate the property.
• Aquino, however, contended in her Answer that the alleged sale was governed by a Memorandum of Agreement (MOA), under which Aure was to secure a bank loan using the property as collateral and remit the loan proceeds to the Aquino spouses. Despite the successful loan, no proceeds were received by Aquino.

Procedural History and Court Proceedings

• Aure and Aure Lending instituted a Complaint for ejectment before the Metropolitan Trial Court (MeTC) of Quezon City, Branch 32, docketed as Civil Case No. 17450.
• The MeTC dismissed the complaint on multiple grounds including failure to exhaust the barangay conciliation process, improper joinder of Aure Lending, and conversion of the case from a mere detainer suit to one involving issues of ownership that are incapable of pecuniary estimation.
• In its ruling, the MeTC emphasized that because the parties were residents of the same barangay and had not attempted barangay conciliation, the suit was premature.
• The Regional Trial Court (RTC) of Quezon City, Branch 88, affirmed the MeTC’s dismissal based on its observation on the mandatory requirement of barangay conciliation in ejectment cases involving residents of the same barangay.
• Respondent Aure filed a Motion for Reconsideration with the RTC, which was denied. He then appealed to the Court of Appeals asserting errors in dismissing the cause on the ground of lack of cause of action.
• On 17 October 2001, the Court of Appeals reversed the decisions of both the MeTC and RTC.
• The appellate court ruled that the failure to resort to barangay conciliation was not a jurisdictional defect and did not affect the sufficiency of the complaint.
• It was held that the allegation of ownership by Aquino did not divest the MeTC of its jurisdiction over the ejectment suit.
• The case was remanded to the MeTC for further proceedings and a determination of the parties’ substantive rights.
• A subsequent Resolution dated 8 May 2002 from the Court of Appeals denied Aquino’s Motion for Reconsideration, holding that her arguments had been previously considered.

Underlying Legal Requirements and Context

• The barangay conciliation process is rooted in Presidential Decree No. 1508 (the Katarungang Pambarangay Law), now incorporated in Republic Act No. 7160 (Local Government Code), which makes conciliation a precondition for judicial filing.
• Section 412 of the Local Government Code mandates that parties must first undergo conciliation before instituting a complaint in court, except under certain exceptions.
• The jurisdictional requirement of the ejectment suit is derived from the Rules of Court, particularly the provisions on forcible entry and unlawful detainer cases, which allow the court to address issues of possession even when the issue of title is incidentally raised.

Issue:

Whether the failure to comply with the barangay conciliation proceedings constitutes a jurisdictional defect that warrants dismissal of the ejectment complaint.

• Aquino argued that non-participation in the barangay conciliation process rendered the suit premature and subject to dismissal.
• The contention included the point that her defense regarding non-compliance was timely raised during pre-trial and in her position paper.

Whether the allegation of ownership by Aquino in her Answer ousts the Metropolitan Trial Court of its jurisdiction over the ejectment case.

• The respondent maintained that the mere assertion of ownership should not strip the court from adjudicating a case primarily for ejectment, which revolves around the issue of possession.
• This issue also touched upon whether the MeTC had jurisdiction to resolve ownership disputes insofar as they are implicated in the determination of possession.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)