G.R. No. 111416-17 - Uy vs. Contreras

Petitioner Felicidad Uy subleased half of the second floor of a building at Reposo and Oliman Streets, Makati, Metro Manila, where she operated a beauty parlor under a contract that expired on 15 April 1993.
Respondent Susanna Atayde was the lessor; private respondent Winnie Javier was one of Atayde’s employees.

On 17 April 1993, Uy attempted to remove remaining movable property (cabinets, shelves, mirror, shampoo bowl, air-conditioning casing) and engaged in an argument that escalated into a scuffle with Atayde and Javier.
The private respondents underwent medical examinations on 21 April 1993, claiming slight physical injuries.

The private respondents filed Barangay Cases Nos. 1023 and 1024 with Barangay Valenzuela, Makati on 23 April 1993; a confrontation was set for 28 April 1993, at which only Uy appeared, prompting a reset to 26 May 1993.
Uy later obtained from the barangay captain a certification dated 18 May 1993 confirming ongoing conciliation efforts.

On 11 May 1993, the Provincial Prosecutor of Rizal filed two informations for slight physical injuries against Uy before the Metropolitan Trial Court (MTC), Branch 61, Makati, docketed as Criminal Cases Nos. 145233 and 145234.
The court required Uy’s counter-affidavit, which she filed on 14 June 1993, asserting prematurity for failure to complete barangay conciliation and attaching the 18 May certification.
On 18 June 1993, Uy moved to dismiss both cases for non-compliance with P.D. No. 1508 (prior barangay referral) and Section 18 of the 1991 Revised Rule on Summary Procedure; the MTC denied the motion on 2 July 1993, finding waiver of conciliation and invoking the exception for cases about to prescribe.
A motion for reconsideration was denied on 5 August 1993, leading to this petition for certiorari under Rule 65.

Whether the MTC acted with grave abuse of discretion in denying the motion to dismiss for failure to comply with the mandatory barangay conciliation requirement under P.D. No. 1508 as carried into the Local Government Code of 1991 (R.A. No. 7160) and the 1991 Revised Rule on Summary Procedure.
Whether the exception allowing direct filing in court when the action is about to prescribe (Section 412(b)(4), Local Government Code) applied to permit the premature filing of the criminal cases.
Whether the prescriptive period for slight physical injuries was correctly considered to have lapsed or remained suspended during barangay conciliation.