Espino v. Legarda
REITERATIONFacts
The Antecedents: Respondent Carmita Legarda filed three separate complaints for accion publiciana against petitioners Benjamin and Rosenda Espino, and Jaime Abeja, alleging ownership of three lots on Altura St., Sta. Mesa, Manila. Petitioners allegedly clandestinely entered the premises, constructed houses without consent, and refused to vacate despite demands and barangay summons. Procedural History: The Regional Trial Court (RTC), Manila, ruled in favor of respondent, ordering petitioners to vacate, remove improvements, and pay compensation. Petitioners appealed to the Court of Appeals (CA), which affirmed the RTC decision in toto. The CA held that the barangay conciliation requirement was met, evidenced by a Certification to File Action, and that petitioners did not object to its presentation or question its validity. Petitioners' motion for reconsideration was denied. The Petition: Petitioners seek review of the CA decision, primarily questioning whether respondent complied with the Katarungang Pambarangay Law (Presidential Decree No. 1508) requiring conciliation before filing a court case. They contend the Certification to File Action was not formally offered as evidence.
Issue(s)
Whether respondent complied with the Katarungang Pambarangay Law requiring prior conciliation proceedings before filing a complaint. Whether the failure of petitioners to object to the lack of prior barangay conciliation proceedings before the trial court constitutes a waiver of such requirement.
Ruling
The petition is denied. The challenged Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of compliance with the Katarungang Pambarangay Law: The Court affirmed the Court of Appeals' finding that respondent complied with the Katarungang Pambarangay Law. This compliance was evidenced by a Certification to File Action issued by the Barangay Chairman, which stated that efforts to amicably settle the dispute were made but failed due to the refusal of the parties to meet. The Court noted that the act of the barangay chairman in issuing the certification enjoys the presumption of regularity in the performance of official duty. Furthermore, the petitioners did not object to the presentation of this certification as evidence during the trial, nor did they question its validity. The Court also considered the respondent's argument that the certification need not be formally offered as evidence since it was deemed admitted by petitioners due to their failure to deny it under oath in their Answer. On the issue of failure to object to the lack of conciliation: Even assuming, for the sake of argument, that respondent did not strictly comply with the barangay conciliation requirement, the trial court could still take cognizance of the case because petitioners failed to object to such lack of conciliation during the hearing. The Court reiterated its ruling in Junson v. Martinez that non-compliance with Presidential Decree No. 1508 does not divest a court of competent jurisdiction if the defendants fail to object seasonably. Such objection must be raised in the Answer or in other appropriate pleadings filed before the court first taking cognizance of the complaint. In this case, petitioners did not raise this objection at the earliest opportunity, thereby waiving their right to question the procedural defect.
Main Doctrine
Non-compliance with the mandatory requirement of prior barangay conciliation proceedings does not divest a court of its jurisdiction over a case if the defendant fails to raise such objection seasonably before the court first taking cognizance of the complaint.