Gonzales v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The petitioner, Gregorio Gonzales, is the owner of an apartment in Caloocan City. He leased three units of this apartment to the private respondents, Evangelista, Luciano and Rosita Sese, and Bautista, for monthly rentals under P200.00. On October 1, 1979, petitioner filed separate complaints for ejectment against the private respondents in the City Court of Caloocan City, asserting his need for the premises for his married children, a ground for ejectment under Batas Blg. 25. 2. Procedural History: The City Court of Caloocan City rendered a decision on January 6, 1981, ordering the ejectment of the private respondents. This decision was affirmed by the Court of First Instance of Rizal, Branch XXXII, upon appeal. After their motion for reconsideration was denied, the private respondents appealed to the Court of Appeals. The Court of Appeals, on October 31, 1981, rendered a decision setting aside the lower courts' rulings and dismissing the ejectment cases. The Court of Appeals' denial of the petitioner's motion for reconsideration on January 5, 1982, led to the present petition. 3. The Petition: The petitioner seeks review of the Court of Appeals' decision, which dismissed the ejectment cases due to the petitioner's alleged failure to comply with the mandatory barangay conciliation process under Presidential Decree No. 1508 prior to filing suit. The petitioner argues that this conciliation process is not jurisdictional and that the private respondents waived any objection by participating in the proceedings without raising the issue of non-compliance in their answers or during the trial.
Issue(s)
Whether the failure to undergo barangay conciliation under P.D. No. 1508 affects the jurisdiction of the court. Whether the private respondents waived their right to question the lack of barangay conciliation.
Ruling
The Supreme Court set aside the decision of the Court of Appeals and reinstated the decision of the City Court, as affirmed by the Court of First Instance. The Court held that the failure to undergo barangay conciliation is not a jurisdictional defect and that the private respondents waived such defect by their active participation in the proceedings.
Ratio Decidendi
On the issue of barangay conciliation affecting jurisdiction: The Court clarified that the conciliation process under Presidential Decree No. 1508 is not jurisdictional. Jurisdiction is conferred by Batas Blg. 129 and the Judiciary Act of 1948. Presidential Decree No. 1508 does not vest jurisdiction in the lupon tagapayapa; it only grants conciliation functions. The lupon is not a court of law and does not decide cases. Therefore, the absence of barangay conciliation does not divest a court of competent jurisdiction of its power to try and decide a case. The Court cited Ebol v. Amin to support the proposition that the conciliation process is not jurisdictional. The Court further explained that jurisdiction is the power to try and decide a case, which is distinct from the conciliation function of the lupon. The Court emphasized that P.D. 1508's purpose is to promote the amicable settlement of disputes at the barangay level, not to oust courts of their jurisdiction. On the issue of waiver: The Court held that even if non-compliance with P.D. No. 1508 could affect the sufficiency of the plaintiff's cause of action, it would not prevent a court of competent jurisdiction from exercising its power of adjudication if the defendants failed to object to such exercise of jurisdiction. In the present cases, there was no allegation in the private respondents' answers that the petitioner failed to invoke the authority of the lupon tagapayapa before filing the cases. Furthermore, the private respondents actively participated in the trial, argued their case, and adduced their evidence. These actions constitute a waiver of the procedural defect. The Court reiterated the principle from Royales v. Intermediate Appellate Court that such non-compliance can be waived by the defendants' failure to object and their active participation in the proceedings.
Main Doctrine
Failure to undergo barangay conciliation proceedings under Presidential Decree No. 1508 is not a jurisdictional defect but a procedural matter that can be waived by the parties' active participation in the judicial proceedings.