Case Summary (G.R. No. 96914)
Factual Background
The lease agreements for the two apartment units, dated December 10, 1984, had been orally renewed on a month-to-month basis. As of October 31, 1988, Dizon had accumulated rental arrears amounting to ₱14,039.00, leading Ledesma to issue letters of demand. When Dizon failed to comply with these demands, the dispute was brought before the Barangay for conciliation, which eventually led to the issuance of a certification allowing Ledesma to file an action in court, necessitated by her son’s assistance due to her psychological concerns.
Progression of the Case
The Manila Metropolitan Trial Court ruled in favor of Ledesma on June 21, 1989, requiring Dizon to vacate the premises and pay the outstanding rents along with attorney's fees. The Regional Trial Court upheld this decision, except for reducing the attorney's fees. However, upon appeal, the Court of Appeals reversed the decisions of the lower courts, dismissing the ejectment complaint on the grounds of lack of cause of action due to procedural issues related to the Katarungang Pambarangay Law, specifically sections 6 and 9 of P.D. 1508.
Legal Issues Raised
Ledesma's appeal raises several assignments of error regarding the Court of Appeals' dismissal of her complaint. Key issues include the assertion that Dizon did not properly raise the defense of non-compliance with the barangay conciliation requirements in the lower courts and should thus be seen as having waived this objection. Furthermore, it was contended that Dizon's claims were self-serving and that the proper procedures set out by law were circumvented by his failure to be summoned properly by the Barangay Chairman.
Canonical Provisions of Law
Section 6 of P.D. 1508 mandates a precondition of conciliation before any complaint can be filed in court, stipulating that there must be a personal confrontation between the parties in the presence of the Lupon Chairman or Pangkat. Meanwhile, Section 9 specifies that parties must appear in person without legal representation unless they qualify as minors or incompetent individuals.
Ruling on the Legal Issues
The Supreme Court ruled that Dizon did not raise the non-compliance issue for the first time on appeal since he stated in his Answer that he had not been summoned, which directly related to the proced
...continue readingCase Syllabus (G.R. No. 96914)
Case Citation
- Court: Supreme Court of the Philippines
- Decision Date: July 23, 1992
- G.R. No.: 96914
- Published in: 286 PHIL. 917
- Division: Second Division
- Justice: Nocon, J.
Parties Involved
- Petitioner: Cecilia U. Ledesma
- Respondents: The Hon. Court of Appeals and Jose T. Dizon
Background of the Case
- Petitioner Cecilia U. Ledesma seeks reversal of the Court of Appeals' decision dated August 30, 1990, which dismissed her ejectment complaint due to lack of cause of action and non-compliance with P.D. 1508 (Katarungang Pambarangay Law).
- The petitioner claims ownership of an apartment building located at 800-802 Remedios Street, Malate, Manila, which was leased to the private respondent at specified monthly rates.
Facts of the Case
- The lease agreements for the apartment units were originally executed on December 10, 1984, and had implicitly renewed on a month-to-month basis.
- The private respondent incurred a total arrears of P14,039.00 as of October 31, 1988, prompting the petitioner to send demand letters.
- Following the failure to settle the arrears, the matter was referred to the Barangay for conciliation, leading to a certification to file action.
- Due to her psychological ailments, the petitioner was assisted by her son during the barangay proceedings.
- The Metropolitan Trial Court (MTC) ruled in favor of the petitioner on June 21, 1989, ordering the private respondent to vacate the premise