Case Summary (G.R. No. L-63277)
Applicable Law
The relevant legal framework is shaped by Presidential Decree No. 1508, known as the Katarungang Pambarangay Law, which mandates that disputes involving individuals should first be referred to the Barangay Lupon for conciliation prior to filing in court. Article 1147 of the Civil Code also plays a significant role, as it delineates the prescriptive period for actions of forcible entry and detainer.
Facts of the Case
Petitioner, who occupied the property at a monthly rental of P500, received a demand for overdue rent from Atty. Reyes on August 28, 1982. After the petitioner's failure to remit payment and vacate the premises, Atty. Reyes filed an ejectment suit on September 16, 1982, without first referring the matter to the Barangay Lupon for conciliation as prescribed by law. The Municipal Trial Court accepted the filing despite petitioner's subsequent motion to dismiss based on lack of jurisdiction.
Trial Court's Ruling
Hon. Julian B. Pogoy, in refusing to dismiss the case, justified the court's jurisdiction based on the clerk's acceptance of the filing and noted adherence to procedural requirements. The trial court's decision did not acknowledge the missing prerequisite of Barangay conciliation, despite recognizing the Chief Justice's circular against accepting complaints not filed with the Barangay Lupon.
Petitioner's Argument
The petitioner contended that the lower court lacked jurisdiction due to the failure to comply with the Barangay conciliation process mandated by PD No. 1508. With reference to Article 1147, she emphasized that the ejectment suit was instituted within the allowable time frame, which should have permitted adequate time for an initial conciliation to take place before pursuing judicial remedies.
Respondent's Justification
In response, Atty. Reyes argued that he was exempt from the conciliation rule based on the Statute of Limitations, claiming it would bar his action against the petitioner. However, this argument was deemed unconvincing since the timeframe for conciliation should not have precluded the timely filing of the suit.
Court's Analysis
The Court found that the underlying requirement for Barangay conciliation was crucial to establish the trial court's jurisdiction as needed under PD 1508. It clarified that while Section 4(a) of the decree requires referral for disputes involving individuals, the case in question involved a juridical persona—the intestate estate—thus exempting it from this requirement
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Case Background
- The case involves a petition filed by Petra Vda. de Borromeo against Hon. Julian B. Pogoy and Atty. Ricardo Reyes.
- The dispute arises from an ejectment suit related to a building owned by the intestate estate of Vito Borromeo, located in Cebu City.
- Petra Vda. de Borromeo has been leasing the building for a monthly rent of P500.00.
Events Leading to the Ejectment Suit
- On August 28, 1982, Atty. Ricardo Reyes, the estate administrator, sent a letter to the petitioner demanding payment for overdue rentals from March to September 1982 and requested her to vacate the premises.
- After Petra failed to comply with the demand, Atty. Reyes filed an ejectment case on September 16, 1982, which was assigned as Civil Case No. R-23915.
Petitioner’s Motion to Dismiss
- On November 12, 1982, Petra filed a motion to dismiss the ejectment case, arguing the trial court lacked jurisdiction due to Atty. Reyes's failure to refer the matter to the Barangay Lupon for conciliation as required by PD No. 1508 (Katarungang Pambarangay Law).
- The respondent judge denied the motion, stating that the case was proper