G.R. No. 91606 , December 17, 1991
Estrella R. Empaynado and Erodita Empaynado, petitioners, vs. Court of Appeals, Elenita Canja and Rolando Canja, respondents.

FACTS

Petitioners Estrella and Erodita Empaynado, owners of a house and lot in Caloocan City, filed an unlawful detainer case against respondents Elenita and Rolando Canja. The Empaynados alleged that the Canjas’ one-year lease contract expired on January 1, 1988, but the Canjas refused to vacate despite subsequent written demands. The petitioners secured a “Certification to File Action” from the barangay captain after the Canjas failed to appear at the scheduled conciliation hearing.
The Canjas defended by claiming the written lease contract was forged and that they had an oral agreement allowing them to stay as long as needed. They also raised the defense that there was no proper conciliation at the barangay level prior to the filing of the case. The Metropolitan Trial Court (MTC) ruled for the Empaynados, ordering the Canjas to vacate. The Regional Trial Court (RTC) affirmed this decision on appeal.

ISSUE

Whether the Court of Appeals correctly dismissed the unlawful detainer complaint on the sole ground of lack of prior barangay conciliation.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the RTC decision. The legal logic centered on the proper application of the Katarungang Pambarangay Law. The Court held that the defense of lack of conciliation was unsubstantiated and had been effectively waived.
The Canjas’ failure to appear at the scheduled barangay hearing was a sufficient basis for the barangay captain to issue the Certification to File Action, as provided by the rules. The petitioners’ affidavit, detailing the Canjas’ non-appearance, remained unrebutted. This created a presumption of regularity in the performance of the barangay captain’s official duty, which the respondents failed to overcome with clear and convincing evidence.
Furthermore, the Court found that the respondents had abandoned this procedural defense. Their judicial admission during the MTC preliminary conference that there was “no possibility of settling the case amicably” confirmed the futility of conciliation and ratified the certification’s validity. The dismissal by the Court of Appeals on this technical ground, despite the substantive merits of the ejectment case and the respondents’ own conduct frustrating conciliation, constituted a grave error. Compliance with barangay conciliation is mandatory, but the law does not require a futile ceremony when a party refuses to participate, as the respondents did here.