G.R. No. L-71091, January 29, 1988
HENRY GALUBA, petitioner, vs. SPOUSES ALFREDO and REVELINA LAURETA, HON. JUDGE BRAULIO YARANON, THE SHERIFF OF BAGUIO CITY, respondents.

FACTS

Petitioner Henry Galuba and respondents Spouses Alfredo and Revelina Laureta entered into an amicable settlement before the Lupong Tagapayapa on February 10, 1984, regarding the unpaid balance of P18,000 from the sale of a house and lot. The settlement stipulated monthly installments, with non-compliance authorizing execution under the Barangay Law. Subsequently, Galuba discovered issues with the property, including encroachment and unpaid bills. On July 17, 1984, he filed an unsworn complaint with the barangay captain seeking annulment of the settlement, alleging his consent was vitiated by mistake or fraud.
Meanwhile, the Lauretas moved for execution of the settlement in the Municipal Trial Court (MTC), which granted the writ. Galuba then filed a complaint in the Regional Trial Court (RTC) for annulment of the amicable settlement with a prayer for injunction. The Lauretas moved to dismiss, arguing lack of jurisdiction because Galuba failed to repudiate the settlement within the 10-day period under P.D. No. 1508 (The Katarungang Pambarangay Law), a precondition to judicial action. The RTC granted the motion to dismiss, holding it lacked jurisdiction.

ISSUE

Whether the Regional Trial Court has jurisdiction to annul an amicable settlement executed under the Katarungang Pambarangay system when the aggrieved party failed to repudiate it within the 10-day period prescribed by law.

RULING

The Supreme Court ruled that the RTC correctly dismissed the complaint for lack of jurisdiction. Under Section 11 of P.D. No. 1508, an amicable settlement attains the force and effect of a final court judgment after ten days from its date, unless it is repudiated. Section 13 provides the exclusive remedy: a party must repudiate the settlement on grounds of fraud, violence, or intimidation by filing a sworn statement with the barangay captain within the ten-day period. Failure to do so constitutes a waiver of the right to challenge the settlement on those grounds.
The law does not provide for a separate judicial action to annul an unrepudiated amicable settlement. The remedy of repudiation supplants a court action for annulment. Since Galuba filed his complaint for annulment only in July 1984, far beyond the ten-day period from February 10, 1984, he lost his right to challenge the settlement. His subsequent filing of an unsworn complaint with the barangay did not constitute a valid repudiation under the law. The primordial objective of P.D. No. 1508 is to reduce court litigations through barangay conciliation. Allowing court actions on unrepudiated settlements would contravene this purpose and exacerbate court congestion. Consequently, the RTC had no jurisdiction to entertain the action. The petition was denied.