GR 153567; (February, 2008) (Digest)
G.R. No. 153567 ; February 18, 2008
Librada M. Aquino, petitioner, vs. Ernest S. Aure, respondent.
FACTS
Respondent Ernest Aure filed a complaint for ejectment against petitioner Librada Aquino before the Metropolitan Trial Court (MeTC). Aure alleged he acquired the subject property from Aquino and her husband via a Deed of Sale, but the spouses refused to vacate after receiving consideration. In her Answer, Aquino countered that the transaction was governed by a Memorandum of Agreement where Aure was to secure a loan using the property as collateral and remit the proceeds to them, which he failed to do. She also raised the defense of lack of prior barangay conciliation.
The MeTC dismissed the complaint, citing non-compliance with the barangay conciliation process, improper joinder of a party, and that the action, due to the raised issue of ownership, was converted into one incapable of pecuniary estimation falling under RTC jurisdiction. The Regional Trial Court (RTC) affirmed the dismissal, emphasizing that barangay conciliation is a mandatory precondition. The Court of Appeals reversed, ruling that failure to conciliate was not a jurisdictional flaw and that the MeTC retained jurisdiction over the ejectment suit despite the allegation of ownership.
ISSUE
The core issue is whether non-compliance with barangay conciliation proceedings is a jurisdictional defect that warrants the dismissal of an ejectment complaint.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The Court held that non-compliance with the barangay conciliation requirement under the Local Government Code is not a jurisdictional defect. It is merely a condition precedent for the filing of the case in court. The conciliation process is designed to promote amicable settlement but failure to observe it does not strip the court of its jurisdiction over the subject matter.
The legal logic is clear: jurisdiction over ejectment cases is conferred by law based on the allegations in the complaint. The MeTC’s jurisdiction is determined solely by the nature of the action as one for unlawful detainer, as pleaded by Aure. Aquino’s assertion of ownership in her answer is a mere defense that does not convert the summary action into a title case or oust the MeTC of its jurisdiction. Furthermore, the Court noted that the objection based on lack of prior conciliation was waived as it was not raised in a motion to dismiss before filing the answer. Consequently, the case was correctly remanded to the MeTC for proceedings on the merits.