Remedial Law

Sebastian v. Ng GR No. 164594, April 22, 2015 Katarungang Pambarangay Law, MTC-Jurisdiction

FACTS:

Michael Sebastian and Annabel Lagmay Ng were sweethearts. While Annabel was working in Hongkong, she sent Michael the amount of P350,000.00 to purchase a truck, as their investment. However, after Annabel and Michael’s relationship had ended, Michael allegedly refused to return the money to Annabel, prompting the latter to bring the matter before the Barangay Justice.

Angelita, acting as representative and attorney-in-fact of her daughter Annabel, filed a complaint before the Barangay Justice of Siclong, Laur, Nueva Ecija, seeking to collect from Michael Sebastian the sum of P350,000.00 that Annabel sent to Michael. 

On July 9, 1997, the parties entered into an amicable settlement, evidenced by a document denominated as “kasunduan” wherein Michael agreed to pay Annabel the amount of P250,000.00 on specific dates. The kasunduan was signed by Angelita (on behalf of Annabel), Michael, and the members of the pangkat ng tagapagkasundo.

After about one and a half years from the date of the execution of the kasunduan, Angelita filed with the MCTC a Motion for Execution of the kasunduan.

The MCTC rendered a decision in favor of Annabel.

On appeal, the RTC upheld the MCTC decision. 

Michael filed a Motion for Reconsideration arguing, among others, that the MCTC does not have jurisdiction over the case since the amount of P250,000.00 (as the subject matter of the kasunduan) is in excess of MCTC’s jurisdictional amount of P200,000.00.

The RTC granted Michael’s MR, and ruled that there is merit in the jurisdictional issue he raised. It dismissed Angelita’s Motion for Execution, and set aside the MCTC Decision.

Angelita subsequently filed a Petition for Review with the CA. The CA granted the petition, and reversed the RTC’s decision.

Michael’s MR was denied, hence, this petition.

ISSUES:

  1. Whether or not the MCTC has the authority and jurisdiction to execute the kasunduan regardless of the amount involved.
  1. Whether the kasunduan has the force and effect of a final judgment.

RULING:

The MCTC has the authority and jurisdiction to enforce the kasunduan regardless of the amount involved.

The Court finds that the CA correctly upheld the MCTC’s jurisdiction to enforce any settlement or arbitration award issued by the Lupon.

We again draw attention to the provision of Section 417 of the Local Government Code that after the lapse of the six (6) month period from the date of the settlement, the agreement may be enforced by action in the appropriate city or municipal court.

The law, as written, unequivocally speaks of the “appropriate city or municipal court” as the forum for the execution of the settlement or arbitration award issued by the Lupon. 

Notably, in expressly conferring authority over these courts, Section 417 made no distinction with respect to the amount involved or the nature of the issue involved. Thus, there can be no question that the law’s intendment was to grant jurisdiction over the enforcement of settlement/arbitration awards to the city or municipal courts regardless of the amount. A basic principle of interpretation is that words must be given their literal meaning and applied without attempted interpretation where the words of a statute are clear, plain and free from ambiguity.

The kasunduan has the force and effect of a final judgment.

Under Section 416 of the Local Government Code, the amicable settlement and arbitration award shall have the force and effect of a final judgment of a court upon the expiration often (10) days from the date of its execution, unless the settlement or award has been repudiated or a petition to nullify the award has been filed before the proper city or municipal court.

Moreover, Section 14, Rule VI of the Katarungang Pambarangay Implementing Rules states that the party’s failure to repudiate the settlement within the period often (10) days shall be deemed a waiver of the right to challenge the settlement on the ground that his/her consent was vitiated by fraud, violence or intimidation.

In the present case, the records reveal that Michael never repudiated the kasunduan within the period prescribed by the law. Hence, the CA correctly ruled that the kasunduan has the force and effect of a final judgment that is ripe for execution.

Leave a Reply

Your email address will not be published.