G.R. No. 260434 - Now Telecom Company, Inc. vs. National Telecommunications Commission

Respondents Victor Go and Flora D. Go filed a complaint on August 5, 1982, in the Court of First Instance of Cebu (now the regional trial courts) seeking the recovery of P49,400 plus damages from petitioners Julius Morata and Ma. Luisa Morata, under Civil Case No. R-22154.
The complaint alleged that all parties were residents of Cebu City, which became relevant to the applicability of the barangay conciliation process as required by Presidential Decree No. 1508 (Katarungang Pambarangay Law).

Petitioners filed a motion to dismiss the complaint based on the contention that the mandatory conciliation process at the barangay level had not been observed. They pointed to the absence of a certification, by the Lupon or Pangkat Secretary, confirming that no amicable settlement or conciliation had been reached prior to filing the suit.
The trial judge, Hon. Valeriano P. Tomol, Jr., issued an order on September 2, 1982, denying the motion to dismiss, relying on the interpretation that Section 6 of PD No. 1508 applied only to cases within the exclusive jurisdiction of the metropolitan and municipal trial courts.

Petitioners filed a motion for reconsideration, which was denied on October 3, 1982. The denial was grounded on the specific reference in Sections 11 and 12 of PD No. 1508 that seemed to limit the application of the mandatory conciliation process to cases under the city and municipal courts.
Subsequent to the denial, petitioners elevated the issue by filing a petition for certiorari and prohibition, seeking to clarify the scope of PD No. 1508 and to challenge the trial court’s order.

Section 6 of PD No. 1508 mandates compulsory conciliation at the barangay level as a pre-condition to filing any judicial complaint or proceeding, except in specific instances (e.g., cases involving detention, deprivation of personal liberty, actions with provisional remedies, or matters where statute of limitations issues may arise).
Section 2 defines the authority of the Lupon to settle disputes among parties residing in the same city or municipality, using the broad term "all disputes" except in enumerated exceptional cases.
The preamble of the law emphasizes promoting amicable dispute resolution, easing court docket congestion, and preserving familial and community ties.

The Court cited Circular No. 22 issued by Chief Justice Enrique M. Fernando directing all judges—including those of the regional trial courts—to desist from receiving complaints that fall under the authority of the barangay Lupon, underscoring the comprehensive applicability of the PD.
A Letter of Implementation from President Ferdinand E. Marcos further stressed the goal of decongesting courts by institutionalizing the barangay conciliation process, irrespective of the court in which the action might originally be filed.

Respondents contended that PD No. 1508 was intended to apply exclusively to cases within the jurisdiction of the inferior (municipal and metropolitan trial) courts.
Petitioners argued that such interpretation would defeat the very purpose of the law by allowing parties to inflate their claims to avoid mandatory conciliation, thereby overburdening regional trial courts with cases that should first be settled at the barangay level.

The Supreme Court granted the petition, clarifying that the conciliation process mandated by PD No. 1508 is compulsory for all actions involving parties residing in the same city or municipality, regardless of whether the case is filed in an inferior or regional trial court.
The Court set aside the trial court’s order and restrained the respondent judge from proceeding further in the case, except to ultimately dismiss the case.

Whether the mandatory conciliation process at the barangay level, as prescribed by Section 6 of PD No. 1508, applies only to cases filed in the metropolitan and municipal trial courts or also to those brought before the regional trial courts (formerly Courts of First Instance).
How to interpret the broad statutory language in Section 2 regarding the Lupon's authority to settle “all disputes” among parties residing in the same city or municipality, in light of the apparent limitation set forth in certain provisions and cited by the trial court.

Whether limiting the application of PD No. 1508 to cases under the jurisdiction of inferior courts would undermine the objective of the law to decongest court dockets and promote the speedy administration of justice through amicable settlements.
Whether the legislative intent as evidenced in the preamble and supporting issuances requires a broad interpretation that encompasses disputes filed in regional trial courts.

How to reconcile the specific references to city and municipal courts in Sections 11, 12, and 14 of the law with the overall comprehensive mandate provided by Sections 2 and 6.
Whether the circulars and directives issued by the Chief Justice and the Office of the President, which extend to all courts including regional trial courts, override the narrow interpretation suggested by the trial judge’s decision.