GR 207707; (August, 2020) (Digest)
G.R. No. 207707 , August 24, 2020
ANTONIO G. NGO, PETITIONER, VS. VISITACION GABELO, ERLINDA ABELLA, PETRA PEREZ, EDUARDO TRAQUENA, ERLINDA TRAQUENA, ULISYS MATEO, ALFONSO PLACIDO, LEONARDO TRAQUENA, SUSANA RENDON, AND MATEO TRINIDAD, RESPONDENTS.
FACTS
Petitioner Antonio G. Ngo filed a complaint for recovery of possession of a parcel of land against the respondents before the Regional Trial Court (RTC) of Manila. Ngo claimed ownership by virtue of a Deed of Absolute Sale. In their Answer, respondents raised, as an affirmative defense, Ngo’s failure to refer the dispute to barangay conciliation as a condition precedent for filing the action. The RTC initially dismissed the complaint for lack of cause of action due to this non-compliance.
Ngo filed a Motion for Reconsideration, arguing the RTC had discretion to suspend proceedings and refer the case for conciliation instead of dismissing it. The RTC granted the motion, reinstated the complaint, and ordered the parties to undergo barangay conciliation, suspending the court proceedings. Respondents challenged this RTC Order via a Petition for Certiorari before the Court of Appeals (CA).
ISSUE
Whether the RTC committed grave abuse of discretion in reinstating the complaint and referring the case to barangay conciliation despite Ngo’s failure to comply with the mandatory precondition of barangay conciliation proceedings.
RULING
The Supreme Court denied Ngo’s Petition and affirmed the CA’s decision. The Court held that compliance with the barangay conciliation process under the Local Government Code is a mandatory precondition for filing a case where the parties reside in the same city or municipality. This requirement is jurisdictional, and failure to comply affects the sufficiency of the plaintiff’s cause of action. The RTC’s initial dismissal of the complaint was correct.
The legal logic is that the law expressly mandates prior recourse to the barangay justice system to decongest court dockets and promote amicable settlement. Once the absence of prior conciliation is properly raised as an affirmative defense, the court’s duty is to dismiss the case for lack of cause of action, not to order suspension and referral. The RTC’s act of reinstating the complaint and ordering conciliation after the defect was raised constituted grave abuse of discretion, as it effectively allowed the curing of a jurisdictional defect after the case had already been filed and contested. The CA correctly nullified the RTC’s orders and dismissed the complaint.