o Contends that the MTC lacked jurisdiction for the DeCastros’
22.SPRINGFIELD V RTC JUDGE
GR NO. 142628
FEBRUARY 6, 2007
Topic: Republic Act 7160 (Local Government Code)
Petitioners: Leo Wee
Respondents: George De Castro
Ponente: Chico-Nazario
Doctrine: The barangay justice system was established primarily as a means of
easing up the congestion of cases in the judicial courts. This could be accomplished
through a proceeding before the barangay courts. Parties are required that the parties
undergo a conciliation process before the Lupon Chairman or the Pangkat ng
Tagapagkasundo as a precondition to filing a complaint in court subject to certain
exceptions
FACTS:
 Petitioner Leo Wee, was at that time renting a certain property from the
respondents, De Castros, in Pob, Alaminos, Pangasinan.
o Wee agreed to pay a monthly rent of P9,000 for the property.
o Wee defaulted 1 month’s rent due to refusal to pay because
refused to pay rent for the De Castros raised his rent from P9k to
P15k
o The De Castros alleged that they came up with an agreement for
such increase and everything was consensual.
 Procedural facts:
o DeCastros went to Lupon Tagapamayapa – failed to amicably
settle, which lead to the issuance by the Barangay Lupon for
certification to file action.
o DeCastros sent demand letter, but Wee stubbornly refused to
pay.
o DeCastros filed with MTC a complaint for ejectment.
 George DeCastro filed the complaint together with his
siblings, Annie, Felomina, and Jesus – BUT – ONLY
George was signed in the certification for non-forum
shopping.
 But also attached were SPAs authorizing George to
file and represent the siblings in his behalf.
 Wee answered that they did not agree to any increase in rent – further,
Wee contended that:
o DeCastros failed to comply with the jurisdictional requirement
of seeking conciliation wit the Barangay
o What was certified by the Barangay Lupon was for the issue
whether there was an increase in rent and NOT ejectment.
complaint was devoid of any allegation that there was “unlawful
withholding” of property (or simply no cause of action).
 MTC – DISMISSED FOR FAILURE TO SEEK CONCILIATION WITH
 On appeal to RTC – Affirmed MTC decision.
o DeCastros cannot fault Wee for paying only the agreed price
(p9,000).
o And that failure to conciliate with Baranggay Lupon barred the
ejectment case – for it was a SINE QUA NON in the filing
 Filed Petition for Review on Certiorari with CA:
o CA – for some reason – reversed MTC and RTC decisions.
o Stated that BL is not a jurisdictional requirement AND upheld
that there was unlawful withholding, albeit, differently worded.
ISSUE:
 W/N the conciliation process in the Barangay Lupon is a jurisdictional
requirement. (YES – because there are exceptions)
HELD/RATIO:
 The barangay justice system was established primarily as a means of easing up
the congestion of cases in the judicial courts. This could be accomplished
through a proceeding before the barangay courts
 To ensure this objective, Section 6 of Presidential Decree No. 1508 requires
the parties to undergo a conciliation process before the Lupon Chairman or
the Pangkat ng Tagapagkasundo as a precondition to filing a complaint in
court subject to certain exceptions. ( Accused under detention, Deprived of
Liberty calling for Habaes Corpus, etc)
 There is no question that the parties to this case appeared before the Barangay
Lupon for conciliation proceedings. There is also no dispute that the only
matter referred to the Barangay Lupon for conciliation was the rental
increase, and not the ejectment of petitioner from the subject property.
This is apparent from a perusal of the Certification to file action in court issued
by the Barangay Lupon on 18 January 2002
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 The question now to be resolved by this Court is whether the Certification
dated 18 January 2002 issued by the Barangay Lupon stating that no settlement
was reached by the parties on the matter of rental increase sufficient to comply
with the prior conciliation requirement under the Katarungang Pambarangay
Law to authorize the respondents to institute the ejectment suit against
petitioner.
The Court rules affirmatively.
 While it is true that the Certification to file action dated 18 January 2002 of the
Barangay Lupon refers only to rental increase and not to the ejectment of
 petitioner from the subject property, the submission of the same for conciliation
before the Barangay Lupon constitutes sufficient compliance with the
provisions of the Katarungang Pambarangay Law.
 Given the particular circumstances of the case at bar, the conciliation
proceedings for the amount of monthly rental should logically and reasonably
include also the matter of the possession of the property subject of the rental,
the lease agreement, and the violation of the terms thereof.