ROYALES VS IAC

G.R. No. L-65072                  January 31, 1984

FACTS:

Sought to be annulled in this petition for review is a final and executory judgment rendered by the City Court [now Metropolitan Trial Court] of Manila in Civil Case No. 057662-CV on ground of lack of jurisdiction. Petitioners contend that the Court did not acquire jurisdiction over the case for failure of respondent Jose Planas, plaintiff therein, to avail of the barangay conciliation process before the filing of the case in court, as required by P.D. 1508, otherwise known as the "Katarungang Pambarangay Law."

RULING: 
In disputes covered by P.D. 1508, as in the case at bar, the barangay conciliation process is a pre-condition for the filing of an action in court. There is no dispute that prior to the filing of the complaint, the case was never referred to the Barangay Lupon for conciliation. In fact, respondent Planas failed to allege in his complaint compliance with this condition precedent. Ordinarily, non-compliance with the condition precedent prescribed by P.D. 1508 could affect the sufficiency of the plaintiff's cause of action and make his complaint vulnerable to dismissal on ground of lack of cause of action or prematurity; 1 but the same would not prevent a court of competent jurisdiction from exercising its power of adjudication over the case before it, where the defendants, as in this case, failed to object to such exercise of jurisdiction in their answer and even during the entire proceedings a quo.