JOSE AUDIE ABAGATNAN v. SPS. JONATHAN CLARITO

FACTS:

The petitioners filed a Complaint for Unlawful Detainer and Damages against the respondents, spouses Jonathan Clarito and Elsa Clarito. The petitioners claimed that they were unlawfully deprived of the use and possession of a portion of their land, which the respondents occupied. The petitioners alleged that some of them were residents of Roxas City while others resided in different cities. The respondents argued that prior barangay conciliation is mandatory and cannot be dispensed with, as some of the petitioners executed a Special Power of Attorney authorizing their co-petitioner, who is a resident of Roxas City, to represent them. The Municipal Trial Court in Cities (MTCC) ruled in favor of the petitioners, and the Regional Trial Court (RTC) affirmed the decision. However, the Court of Appeals (CA) dismissed the petitioners' complaint for failure to comply with the mandatory requirement of prior barangay conciliation, as not all the real parties in interest resided in the same city or municipality. The petitioners filed a Petition for Review on Certiorari assailing the CA's decision. The issue is whether the CA correctly dismissed the complaint for failure to comply with the prior barangay conciliation requirement.

ISSUES:

RULING:

PRINCIPLES:

  • Section 412 of the Local Government Code requires prior barangay conciliation as a mandatory requirement, unless otherwise provided. It is intended to promote the speedy resolution of disputes through alternative dispute resolution methods. Failure to comply with this requirement will result in the dismissal of the complaint without prejudice.

  • The requirement of prior barangay conciliation applies even if not all real parties in interest reside in the same city or municipality. As long as one of the parties resides in the same barangay, the dispute falls within the jurisdiction of the Lupon Tagapamayapa.