In the Philippine justice system, the Katarungang Pambarangay (Barangay Justice System) serves as a compulsory mediation layer designed to declog court dockets. Central to this process is the Certificate to File Action (CFA)—a document that serves as a "golden ticket" for a complainant to elevate a dispute to the regular courts.

A common point of friction arises when one party "walks out" of a mediation session. Does this walkout entitle the other party to a CFA, or can the Punong Barangay (Barangay Captain) or the Pangkat ng Tagapagkasundo (Mediation Panel) refuse to issue it?

The General Rule: Compulsory Conciliation

Under Republic Act No. 7160 (The Local Government Code of 1991), specifically Sections 399 to 422, no complaint, petition, action, or proceeding involving any matter within the authority of the Lupon shall be filed or instituted directly in court unless there has been a confrontation between the parties before the Lupon Chairman or the Pangkat.

The issuance of a CFA is mandatory if:

No settlement was reached despite efforts at conciliation.
The respondent failed to appear for a hearing without a valid reason.
The mediation/conciliation process has exceeded the 15-day (Lupon) or 15-day (Pangkat) period without resolution.

The Legal Effect of a Walkout

A "walkout" is legally interpreted based on who leaves and why. The Katarungang Pambarangay Rules clarify that the essence of the law is "actual confrontation."

1. When the Respondent Walks Out

If the respondent attends the initial hearing but walks out before a settlement is reached, or refuses to participate in further proceedings, they are deemed to have waived their right to mediation.

The Result: The Barangay cannot refuse to issue a CFA to the complainant. The respondent’s walkout is essentially a failure of conciliation due to the respondent's lack of cooperation.

2. When the Complainant Walks Out

If the complainant—the person asking for the CFA—is the one who walks out, the situation changes. A walkout by the complainant can be interpreted as a failure to comply with the mandatory conciliation process.

The Result: The Punong Barangay may temporarily withhold the CFA or dismiss the complaint at the barangay level for "failure to prosecute." A complainant cannot simply show up, say "hello," and walk out to get a CFA; they must participate in good faith.

When Can the Barangay Legally Refuse a CFA?

The Barangay is generally a ministerial body, meaning it must issue the certificate if the legal conditions are met. However, they can refuse or delay issuance in specific scenarios:

Prematurity: If the 15-day mandatory period for the Pangkat to resolve the dispute hasn't elapsed and the parties haven't even attempted to talk, the Captain can insist on further sessions.
Willful Failure to Appear: If the complainant fails to appear or walks out without a valid excuse, the Lupon can dismiss the complaint and refuse to issue a CFA. In fact, the respondent may even be entitled to a certificate to bar the action from being filed in court (Certificate to Bar Action).
Indirect Contempt: A walkout can be seen as a violation of the Lupon’s authority. The Lupon may require the "walking out" party to explain their actions before proceeding with the issuance of any certification.

Remedies Against a Refusal to Issue

If a party has participated in good faith, the other party walked out, and the Barangay Captain still refuses to issue a CFA, the Captain is committing a neglect of duty.

Administrative Complaint: The aggrieved party can file an administrative case against the Punong Barangay before the Sangguniang Panlungsod or Sangguniang Bayan for neglect of duty or refusal to perform ministerial functions.
Petition for Mandamus: A lawyer can file a Petition for Mandamus in court to compel the Barangay Captain to issue the CFA, as it is a duty specifically enjoined by law.
DILG Intervention: One can seek assistance from the Department of the Interior and Local Government (DILG) to mediate the refusal of the local officials.

Summary Table: Walkout Scenarios

Scenario	Consequence	Can Barangay Refuse CFA?
Respondent walks out	Conciliation is deemed failed.	No. They must issue it to the complainant.
Complainant walks out	Complaint may be dismissed for lack of interest.	Yes. Until the complainant complies.
Both parties walk out	Deadlock / No settlement.	No. A CFA must be issued as no settlement is possible.
Walkout due to emergency	Valid excuse for rescheduling.	Yes. They should reset the hearing first.

Legal Note: While the Barangay Justice System is informal, it is a jurisdictional requirement. Filing a case in court without a CFA—when one is required—can lead to the dismissal of the court case on the grounds of "failure to comply with a condition precedent."