Case Digest (G.R. No. 128734)
Facts:
The case involves Angel L. Boleyley as the petitioner and Hon. Clarence J. Villanueva, the Presiding Judge of Branch 7 of the Regional Trial Court in Baguio City, along with Albert S. Surla as the private respondent. The events leading to the case began on August 7, 1996, when Boleyley filed a complaint in the Regional Trial Court of Baguio City against Surla for the collection of a sum of money. The complaint sought P530,000.00 for actual damages, P50,000.00 for moral damages, P30,000.00 for exemplary damages, P30,000.00 as attorney's fees plus P1,000.00 per court hearing, and the costs of suit. On September 13, 1996, Surla filed a motion to dismiss the complaint, arguing that Boleyley had failed to comply with the Revised Katarungan Pambarangay Law, which mandates that disputes must first be referred to the barangay lupon for conciliation or settlement before filing a case in court. Boleyley opposed this motion on September 17, 1996, asserting that Surla was not a resid...
Case Digest (G.R. No. 128734)
Facts:
Background of the Case:
- Petitioner Angel L. Boleyley filed a complaint against private respondent Albert S. Surla in the Regional Trial Court (RTC) of Baguio City on August 7, 1996, for the collection of a sum of money. The amounts claimed were:
- P530,000.00 for actual damages,
- P50,000.00 for moral damages,
- P30,000.00 for exemplary damages,
- P30,000.00 as attorney's fees plus P1,000.00 per court hearing,
- Costs of suit.
Motion to Dismiss:
- On September 13, 1996, private respondent filed a motion to dismiss the complaint, arguing that petitioner failed to comply with the Revised Katarungan Pambarangay Law, which requires disputes to be referred to the barangay lupon for conciliation or settlement before filing in court.
Petitioner's Opposition:
- Petitioner opposed the motion to dismiss on September 17, 1996, claiming that private respondent was not a resident of Baguio City, and thus, the barangay lupon had no authority to mediate the dispute.
Trial Court's Decision:
- On November 29, 1996, the trial court dismissed the case for being premature, as it was not referred to the barangay lupon.
- Petitioner filed a motion for reconsideration on December 5, 1996, reiterating that private respondent was not a resident of Baguio City.
- On February 17, 1997, the trial court denied the motion for reconsideration.
Petition to the Supreme Court:
- Petitioner filed a special civil action for certiorari with the Supreme Court, challenging the trial court's orders.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
The Supreme Court ruled that:
- The jurisdiction of the court is determined by the allegations in the complaint, not by the defenses raised in the answer or motion to dismiss.
- The complaint clearly indicated that the parties did not reside in the same city or municipality, as petitioner resided in Baguio City, while private respondent's address was listed as a postal office address in Baguio City.
- The term "resides" in the context of the Revised Katarungan Pambarangay Law refers to actual residence, not legal residence or domicile.
- Since the parties did not reside in the same city or municipality, the dispute was exempt from the requirement of prior referral to the barangay lupon or pangkat.
- The trial court committed grave abuse of discretion in dismissing the complaint for prematurity, as there was no need for prior referral to the barangay lupon.
Conclusion:
The Supreme Court held that the trial court erred in dismissing the case for failure to refer the dispute to the barangay lupon, as the parties did not reside in the same city or municipality. The case was remanded to the trial court for further proceedings.