Empaynado v. Court of Appeals
REITERATIONFacts
The Antecedents: This case concerns a dispute over the lease of a residential property located at 110 Emilio Jacinto Street, Caloocan City. The petitioners, Estrella R. and Erodita Empaynado, are the owners of the property. The respondent, Elenita Canja, was a lessee whose one-year lease contract, beginning January 1, 1987, expired on January 1, 1988. Despite the expiration, the respondent continued to occupy the premises. The petitioners sent demand letters on August 22, 1988, and October 29, 1988, requesting the respondent to vacate the property, but these demands were ignored. The respondent claimed the lease was not unilaterally terminable and that the written contract was a forgery. Procedural History: The petitioners initiated an unlawful detainer case before the Metropolitan Trial Court (MTC) of Caloocan City, Branch 53, after a conciliation attempt at the barangay level failed, resulting in a Certificate to File Action. The MTC ruled in favor of the petitioners on January 13, 1989, ordering the respondent to vacate and pay damages. The respondent appealed to the Regional Trial Court (RTC) of Caloocan City, Branch 23. On May 10, 1989, the RTC affirmed the MTC's decision in its entirety. Subsequently, the respondent filed a petition for review with the Court of Appeals. The Petition: The Court of Appeals, on October 26, 1989, reversed the RTC's decision and dismissed the unlawful detainer complaint, citing the lack of proper conciliation proceedings at the barangay level as a ground for dismissal. The petitioners are now before the Supreme Court via a petition for review on certiorari, arguing that the Court of Appeals erred in reversing the lower courts' decisions. They contend that the respondent abandoned the defense of lack of barangay conciliation, that the Certification to File Action was valid, and that the respondent failed to present convincing evidence to rebut the presumption of regularity in the barangay captain's actions. The core issue presented to the Supreme Court is whether the Court of Appeals committed a reversible error in holding that no conciliation proceedings occurred at the barangay level pursuant to PD 1508.
Issue(s)
Whether the Court of Appeals committed a reversible error in holding that no conciliation proceedings between the parties occurred at the barangay level pursuant to P.D. 1508, and whether the Certification to File Action was validly issued. Whether the respondents abandoned their defense of lack of barangay conciliation.
Ruling
The Supreme Court set aside the decision of the Court of Appeals and reinstated the decision of the Regional Trial Court. The Court held that the Certification to File Action was validly issued and that the respondents had effectively abandoned their defense of lack of barangay conciliation.
Ratio Decidendi
On the issue of barangay conciliation and the validity of the Certification to File Action: The Court reiterated that the primordial objective of P.D. 1508 is to reduce court litigations. While conciliation is compulsory, it is not a jurisdictional requirement. A review of the records revealed that the Certification to File Action complied with P.D. 1508 and was valid. The respondents alleged the absence of confrontation at the barangay level in their answer but did not seriously pursue this defense in their position paper, focusing instead on more substantial issues. Their subsequent attempt to revive this procedural issue was deemed too late. Furthermore, the parties' admission before the MTC that there was no possibility of amicable settlement underscored the futility of remanding the case to the Katarungang Pambarangay, confirming the validity of the certification. The presumption of regularity in the performance of official duty by the Barangay Captain was not rebutted by convincing evidence. The affidavit of petitioner Estrella R. Empaynado, stating that the respondent Elenita E. Canja failed to appear during the barangay hearing, was not refuted. This non-appearance was considered by the Barangay Captain as a refusal to be mediated, justifying the issuance of the Certification to File Action, in accordance with Rule VI, Section 7 of the applicable rules, which states that failure of the respondent to appear is a sufficient basis for issuing such a certification. On the abandonment of defense: The Court found that the respondents did not seriously and extensively pursue their defense of lack of barangay conciliation. Their position paper did not reiterate this procedural issue, and they instead focused on the merits of the ejectment case. This selective focus indicated an abandonment of the procedural defense. It was only after an adverse ruling from the MTC that they attempted to raise the issue again, which was considered too late. The judicial admission made by the parties before the MTC regarding the impossibility of amicable settlement further demonstrated the futility of the conciliation process and, by extension, the lack of serious pursuit of the defense related to it.
Main Doctrine
The failure of a respondent to appear at a barangay conciliation hearing, despite being summoned, is a sufficient basis for the issuance of a Certification to File Action, and such certification is presumed to have been regularly issued in the absence of convincing contrary evidence. A defense not seriously and extensively pursued in the lower courts may be deemed abandoned.