Case Summary (G.R. No. 111416-17)
Key Dates
15 April 1993
• Expiration of sublease.
17 April 1993
• Physical altercation between petitioner and private respondents.
21 April 1993
• Medical examinations of Atayde and Javier.
23 April 1993
• Barangay complaints filed before Punong Barangay, docketed as Barangay Cases Nos. 1023–1024.
28 April 1993
• First scheduled mediation; petitioner appeared, private respondents did not.
26 May 1993
• Rescheduled mediation.
11 May 1993
• Informations for slight physical injuries filed in MTC Makati (Criminal Cases Nos. 145233–145234).
14 June 1993
• Petitioner’s counter-affidavits and barangay‐mediation certification submitted.
18 June 1993
• Motion to dismiss for lack of prior lupon referral filed.
2 July 1993
• Motion denied by MTC Judge Contreras.
5 August 1993
• Motion for reconsideration denied.
Facts and Procedural History
- Petitioner subleased half of the second-floor premises and operated a beauty parlor. Upon lease expiration, she attempted to remove remaining movable items; an altercation ensued.
- Private respondents claimed slight physical injuries and underwent medical examination.
- They lodged barangay complaints on 23 April 1993; only petitioner attended the 28 April mediation.
- Unresolved at barangay level, informations were filed on 11 May 1993 before the MTC.
- Petitioner invoked prematurity and failure to exhaust barangay conciliation; attached certification of ongoing barangay proceedings.
- Her motion to dismiss under P.D. No. 1508 and Revised Rule on Summary Procedure was denied; petitioner sought certiorari.
Barangay Conciliation Under the Local Government Code
• Section 412(a), LGC 1991—Prior lupon confrontation and certificate of no settlement are conditions precedent to court filing for matters within lupon authority.
• Section 412(b)(4)—Exception for actions that “may otherwise be barred by the statute of limitations.”
• Section 410(c)—Suspension of prescription for up to sixty days from filing with the Punong Barangay.
• Sections 408–409—Defines offenses within lupon authority (including slight physical injuries) and proper venue rules.
Suspension and Computation of Prescriptive Period
• Slight physical injuries punishable by arresto menor or fine not exceeding ₱200 prescribe in two months (Art. 90, RPC).
• Filing with the lupon on 23 April 1993 interrupted prescriptive period; sixty-day suspension extended until 22 June 1993.
• Exception for imminently prescribed offenses does not apply while suspension is in effect.
Jurisprudence on Prior Referral and Prematurity
• P.D. No. 1508 jurisprudence (e.g., Morata v. Go; Vda. de Borromeo v. Pogoy) treats barangay conciliation as condition precedent—non-compliance renders complaint premature.
• Not jurisdictional, but subject to timely motion to dismiss (analogous to exhaustion of administrative remedies).
• Substantial compliance may cure defect if certification issued before trial.
Analysis of Trial Court’s Ruling
- Judge Contreras applied P.D. No. 1508 (Section 6) instead of the repealing LGC 1991 provisions—failure to take judicial notice of the Local Government Code.
- He deemed petitioner to have waived barangay conciliation, citing different residencies—contrary to the fact that both parties pursued barangay proceedings.
- He invoked the statute-of-limitations exception prematurely, disregarding the sixty-day suspension rule under Section 410(c) LGC 1991.
- He failed to penalize private respondents for non-appearance at the initial mediation, which extinguished their right to immediate court filing.
Supreme Court’s Findings
• The disputed offenses fall within lupon authority (slight physical injuries punishable by imprisonment ≤ 1 year or
Case Syllabus (G.R. No. 111416-17)
Facts of the Case
- Petitioner Felicidad Uy subleased half of the second floor of a building in Makati from respondent Susanna Atayde and operated a beauty parlor there.
- The sublease expired on 15 April 1993; petitioner had remaining movable items inside the premises.
- On 17 April 1993, petitioner attempted to retrieve cabinets, shelves, frames, a mirror, a shampoo bowl, and an air-conditioning casing, triggering an argument.
- The argument escalated into a scuffle involving petitioner, Atayde, and Atayde’s employees, including respondent Winnie Javier.
- On 21 April 1993, Atayde and Javier underwent medical examinations for alleged physical injuries.
Barangay Proceedings
- On 23 April 1993, the private respondents filed Barangay Cases Nos. 1023 and 1024 with Barangay Valenzuela, Makati.
- A first confrontation was set for 28 April 1993; only petitioner appeared and the hearing was reset to 26 May 1993.
- No settlement was reached at the barangay level before the second scheduled date.
Criminal Information and Lower Court Actions
- On 11 May 1993, the Provincial Prosecutor of Rizal filed two informations for slight physical injuries (Criminal Cases Nos. 145233 and 145234) against petitioner in the Metropolitan Trial Court (Branch 61, Makati).
- On 21 May 1993, Judge Contreras ordered submission of petitioner’s counter-affidavit and testimonies; these were filed on 14 June 1993.
- Petitioner’s counter-affidavit raised prematurity due to non-compliance with barangay conciliation; included an 18 May 1993 barangay certification of ongoing conciliation.
- On 18 June 1993, petitioner moved to dismiss for lack of prior barangay referral under P.D. No. 1508 and Section 18 of the 1991 Revised Rule on Summary Procedure.
- On 2 July 1993, Judge Contreras denied the motion, reasoning that:
- The offense occurred in Makati and was near prescription.
- Parties resided in different barangays.
- Petitioner waived barangay proceedings and complainants could go directly to court.
- A motion for reconsideration was denied on 5 August 1993.
Petition for Certiorari
- Petitioner filed a Rule 65 certiorari petition before the Supreme Court, challenging Judge Contreras’s or