Case Digest (G.R. No. 96914)
Facts:
Petitioner filed an ejectment action against private respondent alleging unpaid rentals for two leased units and attaching a Barangay Certification to File Action; the Metropolitan Trial Court and the Regional Trial Court ruled for Petitioner. The Court of Appeals reversed and dismissed the complaint for lack of cause of action for non-compliance with P.D. 1508, Sections 6 and 9, prompting this appeal to the Supreme Court.
Issues:
- Did private respondent sufficiently raise non-compliance with Sections 6 and 9 of P.D. 1508 in the lower court so as to permit the Court of Appeals to dismiss for lack of cause of action?
- Did Petitioner personally appear before the Lupon as required by Section 9 or show a valid exception to the personal-confrontation rule?
- Does failure to comply with Sections 6 and 9 of P.D. 1508 bar the filing of an ejectment complaint in court?
Ruling:
The Court affirmed the decision of the Court of Appeals and dismissed Petitioner’s appeal, confirming that the ejectment complaint was barred for non-compliance with P.D. 1508, Sections 6 and 9, and imposed treble costs against Petitioner. The Court held that the defenses of lack of barangay conciliation and absence of personal confrontation were properly raised below and that Petitioner failed to prove any legally cognizable excuse for non-appearance.
Ratio:
The Court found that allegations in the Answer that the defendant was not summoned or subpoenaed and that the certification was irregular amounted to a substantial raising of non-compliance with Sections 6 and 9 of P.D. 1508, thus properly presenting the issue to the trial courts. Documentary evidence showed that Petitioner was represented at the barangay proceedings by her son and counsel, not by personal appearance, and Petitioner did not establish incompetence or another statutory exception to the mandatory personal-confrontation requirement; therefore the statutory preconditions to suit were not met and the complaint lacked cause of action.
Doctrine:
- Sections 6 and 9 of P.D. 1508 establish mandatory preconditions to filing court actions involving matters within Lupon authority.
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