G.R. No. L-62339 October 27, 1983
SPOUSES MARIA LUISA P. MORATA AND JULIUS MORATA, petitioners, vs. SPOUSES VICTOR GO and FLORA C. GO and HON. VALERIANO P. TOMOL, JR., Judge, Court of First Instance of Cebu, Branch XI, respondents.

FACTS

Private respondents, spouses Victor Go and Flora Go, filed a complaint for recovery of a sum of money plus damages amounting to P49,400.00 against petitioners, spouses Julius and Maria Luisa Morata, in the Court of First Instance of Cebu. The complaint alleged that all parties were residents of Cebu City. Petitioners moved to dismiss the complaint on the ground that it failed to allege prior recourse to the barangay conciliation process as required by Presidential Decree No. 1508 (the Katarungang Pambarangay Law) and lacked the requisite certification from the Lupon or Pangkat Secretary.
The respondent judge denied the motion to dismiss. He ruled that the conciliation precondition under P.D. 1508 applied only to cases cognizable by the inferior courts (city or municipal courts), citing Sections 11 and 12 of the law which refer to these courts for the execution or nullification of arbitration awards. Since the complaint was filed in the Court of First Instance (now Regional Trial Court), he held that prior barangay conciliation was not mandatory. Petitioners’ motion for reconsideration was likewise denied, prompting them to file this petition for certiorari and prohibition.

ISSUE

Whether the compulsory conciliation process under Presidential Decree No. 1508 is a precondition for filing an action in the Court of First Instance (Regional Trial Court), or whether its application is limited only to cases within the exclusive jurisdiction of inferior courts.

RULING

The Supreme Court granted the petition, ruling that the barangay conciliation process under P.D. 1508 is mandatory for all disputes within the authority of the Lupon, irrespective of the court where the action is filed, provided no exception applies. The legal logic is anchored on a clear statutory construction of the law. Section 6 of P.D. 1508 states that no complaint involving any matter within the authority of the Lupon shall be filed in court without prior confrontation and a certification of failed settlement. Section 2 defines the Lupon’s authority broadly, covering “all disputes” between parties actually residing in the same city or municipality, except for specific enumerated exclusions such as certain criminal offenses and cases involving the government.
The Court emphasized that the law, as written, makes no distinction based on the jurisdictional amount or the court where the case is to be filed. The universal term “all disputes” is comprehensive. The reference to city or municipal courts in Sections 11 and 12 pertains only to the specific, subsequent procedures for enforcing or nullifying a settlement award, not to the initial precondition for filing. To limit the law’s coverage to inferior courts would defeat its dual objectives: to promote amicable settlement within the community to preserve unity and to decongest court dockets by discouraging indiscriminate filing of all types of cases. Therefore, the respondent judge committed a grave abuse of discretion in denying the motion to dismiss. The case was remanded with instructions to suspend proceedings until the parties complied with the barangay conciliation requirement.