G.R. No. 215009 - Republic vs. Galeno

Petitioners Emiliana Candido and Francisca Candido are the only legitimate children of Agapito Candido and Florencia Santos, as evidenced by the records of marriage and birth.
Their father, Agapito Candido, eventually abandoned his legitimate family and lived with Sagraria Lozada until his death on May 6, 1987.

On May 11, 1990, Sagraria Lozada, together with Jorge Candido, Virginia Candido, Maximina Candido, and Eduardo Candido—who represented themselves as the sole heirs of the late Agapito Candido—executed a Deed of Extra-Judicial Settlement of Estate with Sale.
This deed covered certain parcels of land owned by Agapito Candido, which were sold to private respondent Mila Contreras, and the properties are currently registered under TCT No. T-120656-M.

On November 6, 1990, petitioners filed a civil action (Civil Case No. 697-M-90) before the Regional Trial Court of Bulacan, Branch 18.
Their complaint sought the annulment of the deed, cancellation of TCT No. T-120656-M in the name of Mila Contreras, and the reinstatement of TCT No. 223602 in the name of Agapito Candido (married to Sagraria Lozada).

On December 5, 1990, private respondent Mila Contreras filed a Motion to Dismiss on the ground that petitioners failed to comply with the mandatory barangay conciliation process mandated by Presidential Decree No. 1508 (the Katarungang Pambarangay Law).
Consequently, the trial court issued an Order on July 10, 1991, dismissing the complaint as to Mila Contreras for lack of prior referral to the Lupon (barangay court).
A subsequent Motion for Reconsideration was filed by the petitioners but was denied by an Order dated August 9, 1991, upholding the dismissal on the same ground.

Section 2 of PD No. 1508 mandates that disputes between persons residing in the same city or municipality (or in adjoining barangays) be subject to amicable settlement before the Lupon.
Section 3 provides the venue requirements for such disputes, emphasizing that the process is intended for resolving disputes among parties residing in the same barangay or local unit, except for certain specific cases.

Sagraria Lozada and Jorge Candido reside at Javier Compound, Bo. Sto. Nino, Taytay, Rizal.
Virginia and Maximina Candido reside at Road 2, Dona Faustina Village, San Bartolome, Novaliches, Quezon City.
Eduardo Candido resides at 388 Barrio Paliwas, Municipality of Obando, Bulacan.
Private respondent Mila Contreras resides at San Pascual, Municipality of Obando, Bulacan.
The Register of Deeds of Bulacan is at his official address in Bulacan.

Whether the dismissal of the complaint against private respondent Mila Contreras was proper based on the alleged failure to comply with the mandatory barangay conciliation process under PD No. 1508.

Is the requirement for prior referral to the Lupon applicable when the dispute involves co-defendants residing in different municipalities, cities, or provinces?
Does the presence of parties from different barangays negate the compulsion for conciliation among those who reside within the same municipality?