G.R. No. L-63277, November 29, 1983
Petra Vda. de Borromeo, Petitioner, v. Hon. Julian B. Pogoy, Municipality/City Trial Court of Cebu City, and Atty. Ricardo Reyes, Respondents.

FACTS

Petitioner Petra Vda. de Borromeo is a lessee in a building owned by the intestate estate of the late Vito Borromeo. Private respondent Atty. Ricardo Reyes, the estate administrator, served a demand letter upon petitioner on August 28, 1982, for overdue rentals and to vacate the premises. Upon her failure to comply, Reyes filed an ejectment suit (Civil Case No. R-23915) before the Municipal Trial Court of Cebu City, presided by respondent Judge Julian B. Pogoy, on September 16, 1982.
Petitioner moved to dismiss the case for lack of jurisdiction, contending that the court could not take cognizance of the suit due to the plaintiff’s failure to refer the dispute to the Barangay Lupon for conciliation as required by Presidential Decree No. 1508 (Katarungang Pambarangay Law), since both parties are residents of Cebu City. Respondent judge denied the motion, relying on a presumption of regularity from the Clerk of Court’s acceptance of the complaint for filing. Petitioner then filed this petition for certiorari.

ISSUE

Whether the Municipal Trial Court acquired jurisdiction over the ejectment suit despite the plaintiff’s failure to submit the dispute to barangay conciliation proceedings.

RULING

The Supreme Court dismissed the petition, upholding the trial court’s jurisdiction. The legal logic is anchored on the proper application of PD 1508. The Court clarified that the mandatory conciliation process under Section 4(a) of the decree applies only where the parties are “individuals,” defined as natural persons. It does not extend to disputes where any party is a juridical person.
In this case, the plaintiff, Atty. Ricardo Reyes, sued in his capacity as the judicial administrator of the Intestate Estate of Vito Borromeo. While an administrator may sue under the Rules of Court, the real party-in-interest is the estate itself. An intestate estate is considered a juridical person under Philippine law. Consequently, the dispute involves a juridical entity, not merely individuals. Therefore, the condition precedent of barangay conciliation under PD 1508 was inapplicable.
The Court also found private respondent’s alternative justification—that direct filing was necessary to avoid the statute of limitations—to be without merit. The prescriptive period for ejectment is one year from demand. With the complaint filed less than a month after the August 28, 1982 demand, there was ample time to complete the conciliation process, which has a maximum period of 60 days, before the one-year period would expire. The trial court was ordered to proceed with the case.