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Lansangan v. Caisip, G.R. No.

212987, August 6, 2018

Facts:

This case stemmed from a Complaint for Sum of Money and Damages filed before the
2nd Municipal Circuit Trial Court of Capas-Bamban-Concepcion, Tarlac (MCTC) by petitioner
against respondent Antonio Caisip (respondent).

Petitioner, a resident of Camanse Street, Purok 4, Rose Park, Concepcion, Tarlac, alleged that
respondent, a resident of Barangay Sto. Niño, Concepcion, Tarlac, executed a promissory
note in her favor in the amount of €2,522.00 payable in three (3) installments. As respondent
defaulted in his obligation under the promissory note and refused to heed petitioner's demands
to comply, the latter was constrained to file the said complaint.

Since respondent failed to file any responsive pleading, petitioner moved to declare him in
default and for the MCTC to render judgment, which was granted in an Order. Accordingly, the
case was submitted for resolution.

The MCTC motu proprio dismissed without prejudice the complaint for failure to comply with the
provisions of Republic Act No. (RA) 7160, otherwise known as "The Local Government Code of
1991," which requires the prior referral of the dispute between residents of the same barangay
for conciliation proceedings before the filing of a case in court. RTC and CA affirmed the case.

Issue: Whether or not the CA erred in upholding the motu proprio dismissal of petitioner's
complaint.

Held: YES. As a general rule, the grounds in Section 1, Rule 16 must be invoked by the party-
litigant at the earliest opportunity, as in a motion to dismiss or in the answer; otherwise, such
grounds are deemed waived. As an exception, however, the courts may order the motu
proprio dismissal of a case on the grounds of lack of jurisdiction over the subject matter, litis
pendentia, res judicata, and prescription of action, pursuant to Section 1, Rule 9 of the Rules of
Court.

In Aquino v. Aure, the Court clarified that such conciliation process is not a jurisdictional
requirement, such that non-compliance therewith cannot affect the jurisdiction which the court
has otherwise acquired over the subject matter or over the person of the defendant.

Here, the ground of non-compliance with a condition precedent, i.e., undergoing prior barangay
conciliation proceedings, was not invoked at the earliest opportunity, as in fact, respondent was
declared in default for failure to file a responsive pleading despite due notice. Therefore, it was
grave error for the courts a quo to order the dismissal of petitioner's complaint on said ground.
Hence, in order to rectify the situation, the Court finds it proper that the case be reinstated and
remanded to the MCTC, which is the court of origin, for its resolution on the merits.
Metrobank v. Sandoval, G.R. No. 169677, February 18, 2013

Facts:

The Republic brought a complaint for reversion, reconveyance, restitution, accounting and
damages in the Sandiganbayan against Andres V. Genito, Jr., Ferdinand E. Marcos, Imelda R.
Marcos and other defendants. The action was obviously to recover allegedly ill-gotten wealth of
the Marcoses, their nominees, dummies and agents. Among the properties subject of the action
were two parcels of commercial land located in Tandang Sora (Old Balara), Quezon City, of the
Registry of Deeds of Quezon City registered in the names of Spouses Andres V. Genito, Jr. and
Ludivina L. Genito.

The Republic moved for the amendment of the complaint in order to implead Asian Bank as an
additional defendant. The Sandiganbayan granted the motion. It appears that Asian Bank
claimed ownership of the two parcels of land as the registered owner by virtue of TCT No. N-
201383 and TCT No. N-201384 issued in its name by the Registry of Deeds of Quezon City.
Asian Bank was also in possession of the properties by virtue of the writ of possession issued
by the RTC in Quezon City. When the Republic was about to terminate its presentation of
evidence against the original defendants, it moved to hold a separate trial against Asian Bank.

Issue: Whether or not the Republic was entitled to a separate trial against Asian Bank

Held: No. Separate Trials are Improper. The rule on separate trials in civil actions is found in
Section 2, Rule 31 of the Rules of Court, which reads: Section 2. Separate trials. – The court, in
furtherance of convenience or to avoid prejudice, may order a separate trial of any claim, cross-
claim, counterclaim, or third-party complaint, or of any separate issue or of any number of
claims, cross-claims, counterclaims, third-party complaints or issues.

The text of the rule grants to the trial court the discretion to determine if a separate trial of any
claim, cross-claim, counterclaim, or third-party complaint, or of any separate issue or of any
number of claims, cross-claims, counterclaims, third-party complaints or issues should be held,
provided that the exercise of such discretion is in furtherance of convenience or to avoid
prejudice to any party.

The general rule is that all issues in every case must be tried at one time. Exceptions to the
general rule are permitted only when there are extraordinary grounds for conducting separate
trials on different issues raised in the same case, or when separate trials of the issues will avoid
prejudice, or when separate trials of the issues will further convenience, or when separate trials
of the issues will promote justice, or when separate trials of the issues will give a fair trial to all
parties. Otherwise, the general rule must apply.

Here, Sandiganbayan committed grave abuse of its discretion in ordering a separate trial as to
Asian Bank (Metrobank) on the ground that the issue against Asian Bank was distinct and
separate from that against the original defendants. The justification of the Sandiganbayan for
allowing the separate trial did not constitute a special or compelling reason like any of the
exceptions. To begin with, the issue relevant to Asian Bank was not complicated. In that
context, the separate trial would not be in furtherance of convenience. And, secondly, the cause
of action against Asian Bank was necessarily connected with the cause of action against the
original defendants.