Morata vs Go

Posted on June 21, 2013 Spouses Morata vs Spouses Go 125 SCRA 444 GR No. L-62339 FACTS: On August 25, 1982, the spouses Go filed a complaint eagainst petitioners orata for reco!er" of a sum of mone" plus damages amounting to P#9,#00$ On the %asis of the allegation that the parties&litigants are all residents of 'e%u 'it", petitioner filed a motion to dismiss citing as grounds the failure of the complaint to allege prior a!ailment %" the plaintiffs of the %aranga" conciliation process re(uired %" P) 1508, as *ell as the a%sence of certification %" the +upon or Pang,at -ecretar" that no conciliation.settlement has %een reached %" the parties$ /he motion to dismiss *as denied on -eptem%er 2, 1982$ /he petitioners0 motion for reconsideration *as also denied on Octo%er 3, 1982$ ISS !: 1hether the conciliation process at the %aranga" le!el, prescri%ed %" P) 1508 as a precondition for filing a complaint in court, is also compulsor" for actions cogni2a%le %" the 3/'$ "!L#: 4es$ Se$.6% &# 15'( pro!ides that the confrontation of the parties and conciliation %efore the +upon is a precondition for filing a complaint, e5cept *hen6 1$ /he accused is under detention7 2$ A person has other*ise %een depri!ed of personal li%ert" calling for 8ha%eas corpus8 proceedings7 3$ Actions coupled *ith pri!isional remedies7 and #$ 1here the action ma" %e %arred %" the -tatute of +imitations$ Se$.2 pro!ides additional e5ceptions, such as *hen6 1$ One part" is the go!ernment, or an" su%di!ision or instrumentalit"7 2$ One part" is a pu%lic officer.emplo"ee and the dispute relates to the performance of his official functions7 3$ Offenses punisha%le %" imprisonment e5ceeding 30 da"s or a fine e5ceeding P2007 #$ 1here there is no pri!ate offended part"7 and

5$ -uch other classes of disputes *hich the Prime inister ma", in the inetrest of 9ustice, determine upon recommendation of the inister of Justice and the inister of +ocal Go!ernment$ /hus, e5cept in the instances enumerated in -ecs$ 2 and : of the la*, the Lupon has the authority to settle amicably all types of disputes involving parties who actually reside in the same city or municipality. /he la* ma,es no distinction *hatsoe!er *ith respect to the classes of ci!il disputes that should %e compromised at the %aranga" le!el$ 1here the la* does not distinguish, *e should not distinguish$ By compelling the disputants to settle their differences through the intervention of the barangay leader and other respected members of the barangay, the animosity generated by protracted court litigations between members of the same political unit, a disrupti!e factor to*ard unit" and cooperation, is avoided$ ;t must %e %orne in mind that the conciliation process at the %aranga" le!el is also designed to discourage indiscriminate filing of cases in court in order to decongest its clogged doc,ets and enhance the (ualit" of 9ustice dispensed %" it$ /he la* o%!iousl" intended to grant the +upon as %road and comprehensi!e authorit" as possi%le as *ould %ring a%out the optimum reali2ation of the aforesaid o%9ecti!es$ /hese o%9ecti!es *ould onl" %e half&met and easil" th*arted if the +upon0s authorit" is e5ercised onl" in cases falling *ithin the e5clusi!e 9urisdiction of inferior courts$ Jurisdiction o!er cases in!ol!ing real propert" or an" interest therein, e5cept forci%le entr" and detainer cases, has al*a"s %een !ested in the 'ourts of <irst ;nstance$ /he authorit" of the +upon is clearl" esta%lished in -ec$2 of the la*7 *hereas -ecs$ 11, 12 and 1# deal *ith the nullification or e5ecution of the settlement or ar%itration a*ards o%tained at the %aranga" le!el$ /hese sections conferred upon the cit" = municipal courts the 9urisdiction to pass upon and resol!e petitions or actions for nullification or enforcement of settlement.ar%itration a*ards issued %" the +upon, regardless of the amount in!ol!ed or the nature of the original dispute$ >ut there is nothing in the conte5t of said sections to 9ustif" the thesis that the mandated conciliation process in other t"pes of cases applies e5cluisi!el" to said inferior courts$ /herefore, t)e $o*$+,+at+o* pro$ess at t)e -ara*.a/ ,eve,, prescri%ed %" P$)$ 1508 as a pre& condition for filing a complaint in court, +s $o0pu,sor/ *ot o*,/ 1or $ases 1a,,+*. u*2er t)e e3$,us+ve $o0pete*$e o1 t)e 0etropo,+ta* a*2 0u*+$+pa, tr+a, $ourts% -ut 1or a$t+o*s $o.*+4a-,e -/ t)e re.+o*a, tr+a, $ourts as 5e,,$ MORATA v. GO (1983)
FACTS: Spouses Victor and Flora Go filed a complaint against spouses Julius and Ma. Luisa Morata for recovery of a sum of money plus damages amounting to P49,4 . in !F" !e#u. $n t%e #asis of t%e allegation in t%e complaint t%at t%e parties&litigants are all residents of !e#u !ity, t%e Moratas filed a motion to dismiss, citing as grounds t%erefor, t%e failure of t%e complaint to allege prior availment #y t%e Gos of t%e #arangay conciliation process re'uired #y P.(. )* +, as ,ell as t%e a#sence of a certification #y t%e Lupon or Pang-at Secretary t%at no conciliation or settlement %ad #een reac%ed #y t%e parties. .%e motion ,as opposed #y t%e Gos. .%e /udge denied t%e motion to dismiss, ruling t%at t%e provision of Sec 0 of t%e la, applies only to cases cogni1a#le #y t%e inferior courts mentioned in Secs )) and )2 of t%e la,. ISSUE: 3$4 t%e complaint s%ould #e dismissed for failure to comply ,it% P( )* +

HELD/RATIO: 56S. .%e nature of t%e case at #ar does not fall under t%e e7ceptions cited in Sections 2 and 0 of P.(. )* +. Since t%e la, does not distinguis%, t%is case8dispute s%ould %ave #een first settled amica#ly #y t%e Lupon. Furt%ermore, t%ere is no s%o,ing t%at t%at t%e intention of t%e la, is to restrict its coverage only to cases cogni1a#le #y t%e inferior courts for it ,ould not %ave included t%e rule on venue provided in Section 9 :pertaining to land disputes ,%ic% are traditionally cogni1a#le #y !F"s8;.!s< t%ereof. .%is is furt%er supported #y !ircular 4o. 22 issued #y t%en !J Fernando ,%ic% gave notice to all !F"s to recogni1e t%e =atarungang Pam#arangay La, and desist from acting upon cases falling ,it%in t%e aut%ority of t%e Lupons. .%is circular ,as noted #y President Marcos. >ence, t%e !ourt declared t%at t%e conciliation process at t%e #arangay level, prescri#ed #y P.(. )* + as a pre&condition for filing a complaint in court, is compulsory not only for cases falling under t%e e7clusive competence of t%e metropolitan and municipal trial courts, #ut for actions cogni1a#le #y t%e regional trial courts as ,ell. Purpose of the Law. ?y compelling t%e disputants to settle t%eir differences t%roug% t%e intervention of t%e #arangay leader and ot%er respected mem#ers of t%e #arangay, t%e animosity generated #y protracted court litigations #et,een mem#ers of t%e same political unit, a disruptive factor to,ard unity and cooperation, is avoided. "t must #e #orne in mind t%at t%e conciliation process at t%e #arangay level is li-e,ise designed to discourage indiscriminate filing of cases in court in order to decongest its clogged doc-ets and, in t%e process, en%ance t%e 'uality of /ustice dispensed #y it. .%us, to say t%at t%e aut%ority of t%e Lupon is limited to cases e7clusively cogni1a#le #y t%e inferior courts is to lose sig%t of t%is o#/ective. 3orse, it ,ould ma-e t%e la, a self&defeating one. For ,%at ,ould stop a party, say in an action for a sum of money or damages, as in t%e instant case, from #loating up %is claim in order to place %is case #eyond t%e /urisdiction of t%e inferior court and t%ere#y avoid t%e mandatory re'uirement of P.(. )* +@ And ,%y, indeed, s%ould t%e la, see- to ease t%e congestion of doc-ets only in inferior courts and not in t%e regional trial courts ,%ere t%e log&/am of cases is muc% more serious@ "ndeed, t%e la,ma-ers could not %ave intended suc% %alf& measure and self&defeating legislation.