Title
Candido vs. Macapagal
Case
G.R. No. 101328
Decision Date
Apr 7, 1993
Petitioners contested an extra-judicial estate settlement, alleging exclusion as heirs. Trial court dismissed due to non-compliance with barangay conciliation; SC reversed, remanding case as not all parties resided in the same jurisdiction.
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Case Digest (G.R. No. 101328)

Facts:

Family Background and Dispute Over Property

  • Petitioners Emiliana and Francisca Candido are the only legitimate children of spouses Agapito Candido and Florencia Santos, as evidenced by their birth certificates and their parents' marriage record.
  • Agapito Candido left his legitimate family and lived with Sagraria Lozada until his death on May 6, 1987.

Extra-Judicial Settlement of Estate

  • On May 11, 1990, Sagraria Lozada, Jorge Candido, Virginia Candido, Maximina Candido, and Eduardo Candido executed a Deed of Extra-judicial Settlement of Estate with Sale, claiming to be the sole heirs of Agapito Candido.
  • The deed covered parcels of land owned by Agapito Candido, which were sold to private respondent Mila Contreras. The properties were subsequently registered under TCT No. T-120656-M in Contreras' name.

Filing of the Complaint

  • On November 6, 1990, petitioners filed a complaint with the Regional Trial Court (RTC) of Bulacan, Branch 18, in Civil Case No. 697-M-90.
  • The complaint sought to annul the Deed of Extra-judicial Settlement of Estate with Sale, cancel TCT No. 120656-M, and reinstate TCT No. 223602 in Agapito Candido's name.

Motion to Dismiss

  • On December 5, 1990, private respondent Mila Contreras filed a Motion to Dismiss, arguing that petitioners failed to comply with the mandatory barangay conciliation process under Presidential Decree No. 1508 (Katarungang Pambarangay Law), as she and the petitioners reside in the same municipality.

Trial Court's Decision

  • On July 10, 1991, the trial court dismissed the case against Mila Contreras for lack of jurisdiction due to the petitioners' failure to comply with the barangay conciliation process.
  • Petitioners filed a Motion for Reconsideration, which was denied on August 9, 1991.

Issue:

  1. Whether the trial court committed grave abuse of discretion in dismissing the case against Mila Contreras for failure to comply with the barangay conciliation process under P.D. No. 1508.
  2. Whether the barangay conciliation process is mandatory when some defendants reside in different municipalities or cities.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court ruled that the trial court erred in dismissing the case against Mila Contreras for failure to comply with the barangay conciliation process. The case was remanded to the RTC for further proceedings.


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