G.R. No. 85475 June 30, 1989
MANUEL A. RAMOS, petitioner, vs. THE HONORABLE COURT OF APPEALS and DOMINGO RAMOS, respondents.

FACTS

Domingo Ramos authorized his brother Manuel Ramos to sell his share of their commonly owned lands. Manuel executed the sale. Domingo later revoked the power of attorney and demanded an accounting, which Manuel refused. Domingo filed a complaint for amicable settlement before the Punong Barangay. At the scheduled hearing, Manuel appeared, but Domingo did not. Domingo’s wife appeared instead, stating her husband wished to avoid a direct confrontation, and requested a certification to file in court. The Punong Barangay issued a certification that no settlement was reached.
Domingo then filed an accounting case against Manuel in the Regional Trial Court. Manuel moved to dismiss, arguing non-compliance with P.D. No. 1508 (Katarungang Pambarangay Law), as the dispute was not referred to the Pangkat ng Tagapagkasundo after the failed mediation before the Punong Barangay. The trial court denied the motion. The Court of Appeals affirmed, holding referral unnecessary as Domingo’s refusal to appear indicated no settlement was possible.

ISSUE

Whether the Regional Trial Court acquired jurisdiction over the complaint despite non-compliance with the mandatory conciliation procedure under P.D. No. 1508, specifically the failure to refer the dispute to the Pangkat ng Tagapagkasundo.

RULING

The Supreme Court ruled in favor of petitioner Manuel Ramos and ordered the dismissal of the civil case. The Court held that there was a failure to comply with the mandatory procedure under P.D. No. 1508, which is a condition precedent for judicial recourse.
The legal logic is anchored on the clear provisions of P.D. No. 1508. Section 4(b) mandates that if the Barangay Captain fails to secure a settlement within fifteen days, he must forthwith set a date for the constitution of the Pangkat. Section 6 explicitly states that no judicial complaint shall be filed unless there has been a confrontation before the Lupon Chairman or the Pangkat and no settlement has been reached, as certified. The law’s dual purposes are to promote amicable settlement through direct confrontation and to decongest court dockets.
The Court found that the proceedings improperly terminated at the mediation stage before the Punong Barangay. His failure to effect a settlement did not authorize him to bypass the Pangkat. The law envisions a second chance for settlement by the Pangkat, which might succeed where the Barangay Captain failed. Moreover, the Punong Barangay could have issued summons to compel Domingo’s attendance under Section 4(d). Domingo’s refusal to appear in person—appearing through his wife violated Section 9 requiring personal appearance—was not a justifiable reason to dispense with the Pangkat. As the complainant who initiated the barangay proceeding but then disregarded it, Domingo was barred under Section 4(d) from seeking judicial recourse. The case of Alinsugay v. Cagampang was distinguished, as there the parties invoking non-compliance were the ones who did not appear, unlike here where the complying party (Manuel) is invoking the defect against the non-appearing complainant (Domingo). Thus, the certification issued was premature and the subsequent court action was procedurally infirm.