GR L 60083; (October, 1982) (Digest)
G.R. No. L-60083 October 27, 1982
Crispina Peñaflor vs. Hon. Domingo Panis, et al.
FACTS
Petitioner Crispina Peñaflor, owner of a residential house in Olongapo City but residing in Dinalupihan, Bataan, filed an ejectment suit against her lessee, Prescilla de los Santos, before the City Court of Olongapo. The lessee moved to dismiss the complaint for failure to refer the dispute to the Lupon Barangay for conciliation as required by Presidential Decree No. 1508 (the Katarungang Pambarangay Law). The City Court denied the motion, ruled in favor of the lessor, and ordered ejectment.
On appeal, the Court of First Instance of Zambales reversed and dismissed the complaint. It held that since the dispute involved an interest in real property, it should have been brought first before the Lupon of the barangay where the property is situated. The lessor filed this petition, alleging grave abuse of discretion.
ISSUE
Whether the ejectment suit should have been brought first before the Lupon Barangay for conciliation as a precondition to judicial filing.
RULING
No. The Supreme Court set aside the dismissal order and directed the reinstatement of the appeal. The legal logic is anchored on the jurisdictional prerequisites of P.D. 1508. For the Lupon’s conciliation process to be mandatory, the dispute must fall within its authority as defined in Sections 2 and 3. A core requirement is that the parties must actually reside in the same city or municipality, or in barangays within the same city/municipality, or in adjoining barangays of different cities/municipalities.
Here, the parties resided in different municipalities (Olongapo City and Dinalupihan, Bataan). Their barangays did not adjoin. Thus, no Lupon Barangay had jurisdiction over their dispute from the outset. The proviso in Section 3, stating that disputes involving real property “shall be brought in the barangay where the real property… is situated,” is merely a rule on venue. It applies only after jurisdiction is established. It does not confer jurisdiction where the residential requirements of the law are absent. Since no Lupon had jurisdiction, the conciliation precondition did not apply, and the lessor correctly filed the ejectment suit directly in court.