VALENZUELA TERESA HOMEOWNERS ASSOCIATION, INC.

vs.

CELSO UMALI

G.R. NO. 244590 : November 13, 2019

Valenzuela Teresa Homeowners Association, Inc. (VALTEHA) is the registered owner of a parcel of land.
Celso, now deceased, was a member of VALTEHA. The latter discovered that the concrete structure built
by the respondents encroached a portion of its lot. VALTEHA filed an accion publiciana before the RTC
which favored the latter. Upon appeal by the respondents, the CA referred the parties to VALTEHA’s
Grievance and Adjudication Committee pursuant to its By-Laws because the action filed by VALTEHA was
a violation thereof. The Committee then ruled in favor of VALTEHA, on appeal, the BOD of VALTEHA
affirmed the decision of the Committee.

Subsequently, VALTEHA instituted accion publiciana against the respondents over the same disputed
area. However, the MeTC and RTC (upon appeal), dismissed the complaint on the ground that it is
barred by prior judgement of the Committee.

Issue:

Whether the Alternative Dispute Resolution is a pre-condition for filing a complaint in court.

Held:

No. the parties who have agreed to settle their dispute through arbitration must accept the
consequences of the arbitral proceeding. As a policy, the court must not interfere in the merits of an
arbitral award and, in the process, bail-out parties who are not satisfied with the outcome of the
proceedings.

While it was an error for the petitioner to file an accion publiciana in MeTC, the intention of petitioner in
filing the petition is intended to enforce the arbitral award pursuant to Rule 11 of the SADR and Section
40 of R.A. 9285. Wherefore, the case was remanded to the RTC to be considered as one for
confirmation/enforcement of arbitral award.