G.R. No. 189602 - Heirs of Zabala vs. Court of Appeals

Case Summary (G.R. No. 189602)

Procedural and Factual Antecedents

On April 1, 2002, respondent Vicente T. Manuel filed a Complaint for ejectment with damages with the Municipal Trial Court in Cities (MTCC) of Balanga, Bataan. Respondent alleged that he had actual and peaceful possession of the fishpond and that Zabala had entered the fishpond without authority on October 15, 2001, dumping soil without an Environment Compliance Certificate. Respondent further alleged that Zabala continued those actions up to the filing of the complaint, allegedly killing the crabs and bangus being raised by respondent. Respondent prayed for injunctive restraint, permanent ejectment, and payment of actual and moral damages and attorney’s fees.

Zabala promptly moved for dismissal, asserting non-compliance with the barangay conciliation requirement under the Local Government Code, before resorting to court. Respondent later filed a Motion for Judgment based on Zabala’s supposed failure to file a responsive pleading. By an Order dated May 27, 2003, the MTCC granted the motion to dismiss and dismissed the complaint, reasoning that respondent indeed violated the requirement of barangay conciliation.

RTC Proceedings and Ruling

Respondent appealed to the Regional Trial Court (RTC) of Balanga, Bataan. In a decision dated March 30, 2004, the RTC reversed the MTCC’s order and directed Zabala, his heirs, or subalterns to vacate Lot No. 1483 and restore respondent to peaceful possession. The RTC also ordered Zabala to pay actual damages, moral damages, and attorney’s fees. The RTC’s ruling rested in part on its finding that Zabala did not, in fact, file an answer to the complaint; it invoked Section 6 of the Revised Rules on Summary Procedure, concluding that respondent was entitled to judgment on the pleadings. It further held, based on the complaint’s allegations, that respondent was entitled to the reliefs prayed for.

Court of Appeals Ruling and Modification

Zabala filed a Petition for Review before the Court of Appeals (CA). On December 19, 2008, the CA promulgated a decision upholding the RTC’s reversal of the MTCC. The CA ruled that the barangay conciliation requirement under the Local Government Code was inapplicable to the suit before the MTCC because the case was one for ejectment and damages, with an application for a writ of preliminary injunction, even though those exact terms did not appear in the complaint. Still, the CA modified the awards by granting Zabala’s request to delete the awards for actual and moral damages and for attorney’s fees.

Zabala’s motion for reconsideration was denied in a resolution dated August 26, 2009.

Supreme Court Petition and Alternative Reliefs

On October 9, 2009, Zabala’s heirs filed a Verified Petition for Certiorari before the Supreme Court. They prayed for the annulment of the CA decision and resolution and sought the reinstatement of the MTCC’s order dismissing the complaint. In the alternative, they asked that the records be remanded to the MTCC so that they could file an answer and that due proceedings be undertaken before judgment.

Compromise Agreement Submitted for Approval

During the pendency of the petition, the parties presented before the Court a Compromise Agreement dated April 8, 2010, and asked for judicial approval. The compromise stated, among others: (1) private respondents acknowledged that petitioners were the owners of the subject parcel of land and improvements; (2) private respondents had filed an ejectment case against the owners in the lower court, which had granted reliefs sought due to petitioners’ failure to file an answer; and (3) in consideration of Two Hundred Thousand Pesos (P200,000.00), private respondents acknowledged receipt of the amount, abandoned the decision rendered in their favor by the lower courts, and waived all rights and interests to the subject property, particularly their right to possession, thereby assuring petitioners a peaceful, continuous and notious (sic) possession of the property.

The parties prayed that the Supreme Court approve the compromise agreement.

Legal Basis and Reasoning

The Court treated the compromise as a contract within the meaning of Article 2028 of the Civil Code, under which a compromise agreement is one where parties, through reciprocal concessions, either avoid litigation or put an end to one already commenced. The Court recognized compromise as an amicable settlement that is not merely allowed but is also encouraged in civil cases. The Court further cited Civil C

Case Syllabus (G.R. No. 189602)

The parties to the Petition for Certiorari sought the Court’s approval of a Compromise Agreement to resolve the controversy.
The Petitioners were the Heirs of Alfredo Zabala, represented by Menegilda Zabala, Rolando Zabala, Manuel Zabala, Marilyn Zabala, and Adelina Zabala.
The Respondents were Hon. Court of Appeals, Vicente T. Manuel, and/or Heirs of Vicente T. Manuel.
The procedural posture placed the matter before the Supreme Court through a Petition for Certiorari, not for further adjudication on the merits, but for the Court’s sanction of a settlement already reached by the litigants.

Originating Ejectment Suit

Respondent Vicente T. Manuel filed a Complaint for ejectment with damages before the MTCC of Balanga, Bataan on April 1, 2002.
Respondent alleged that he had actual and peaceful possession of a fishpond identified as Lot No. 1483 located in Ibayo, Balanga City.
Respondent claimed that petitioner Alfredo Zabala entered the fishpond on October 15, 2001 without authority and dumped soil without an Environment Compliance Certificate.
Respondent alleged that such unauthorized acts continued until the filing of the complaint, and that they killed the crabs and bangus he was raising.
Respondent sought reliefs including a restraining order against further touching and destroying of the fishpond, permanent ejectment, and actual and moral damages plus attorney’s fees.
Petitioner promptly sought dismissal on the ground of non-compliance with the barangay conciliation requirement allegedly mandated before court action under the Local Government Code.

MTCC Ruling

The MTCC issued an Order dated May 27, 2003 granting Zabala’s motion and dismissing the complaint.
The MTCC ruled that respondent violated the requirement of prior barangay conciliation.
The dismissal order became the basis for respondent’s subsequent appeal to the Regional Trial Court.

RTC Reversal and Judgment

Respondent appealed to the RTC of Balanga, Bataan, which rendered a decision dated March 30, 2004.
The RTC reversed the MTCC’s May 27, 2003 Order and directed Zabala and related parties to vacate Lot No. 1483 and to restore respondent to peaceful possession.
The RTC also directed payment of actual damages, moral damages, and attorney’s fees.
The RTC found that Zabala did not in fact file an answer to the complaint.
Applying Section 6 of the Revised Rules on Summary Procedure, the RTC held that respondent was entitled to judgment on the pleadings.
The RTC further ruled that, based on the allegations in the complaint, respondent was entitled to the reliefs prayed for.

CA Decision and Modification

Zabala filed a Petition for Review before the Court of Appeals.
On December 19, 2008, the CA promulgated a decision upholding the RTC’s reversal of the MTCC’s dismissal.
The CA ruled that the barangay conciliation requirement under the Local Government Code was inapplicable to the suit before the MTCC.
The CA reasoned that the action was one for ejectment and damages with an application for a writ of preliminary injunction, even if the complaint did not explicitly use those terms.
Despite affirming the RTC’s reversal, the CA granted Zabala’s pray