TL;DR

The Supreme Court affirmed that raising the issue of a court’s lack of jurisdiction must be done promptly. In this case, after nearly three decades of actively participating in court proceedings, the petitioners were barred from questioning the Regional Trial Court’s jurisdiction because they only raised it at the Supreme Court level. This principle of estoppel by laches prevents parties from belatedly challenging jurisdiction after actively engaging with the court and awaiting an unfavorable outcome. The ruling underscores that while jurisdictional questions are typically fundamental, a party’s prolonged silence and participation can constitute a waiver of their right to raise this issue, especially when it would prejudice the opposing party and undermine judicial efficiency.

Thirty Years of Silence: When Delaying a Jurisdictional Challenge Backfires

Imagine litigating a land dispute for almost thirty years, going through trial court and appeals court, only to question the trial court’s authority for the first time at the Supreme Court. This was the situation in Sps. Rebamonte v. Sps. Lucero. The core legal question revolved around whether the petitioners could belatedly challenge the jurisdiction of the Regional Trial Court (RTC) after decades of active participation in the legal process. The petitioners argued that because the assessed value of the land was below PHP 20,000, the case should have been filed in the Municipal Trial Court (MTC), not the RTC. However, the Supreme Court considered whether their decades-long silence on this jurisdictional issue constituted a waiver, applying the doctrine of estoppel by laches.

The case began with a complaint filed by the Lucero spouses in 1990 to recover land portions occupied by the Rebamonte spouses. The Rebamontes actively participated in the RTC proceedings for over two decades, filing answers, counterclaims, motions for reconsideration, and appealing to the Court of Appeals (CA). It was only when they reached the Supreme Court that they raised the issue of the RTC’s lack of jurisdiction. The Supreme Court acknowledged that generally, jurisdiction can be raised at any stage. However, it emphasized the well-established exception: estoppel by laches. This doctrine, rooted in equity and fairness, prevents a party from asserting a right when their prolonged inaction or silence has prejudiced the opposing party.

The Supreme Court heavily relied on the landmark case of Tijam v. Sibonghanoy, which established the principle that a party cannot invoke a court’s jurisdiction to seek a favorable outcome and then, upon failing to achieve it, question that very jurisdiction. The Court highlighted the circumstances present in Tijam and found them even more pronounced in the current case. Crucially, the Rebamontes were aware of the assessed value of the property from the beginning, as it was stated in the complaint. Despite this knowledge, they never questioned the RTC’s jurisdiction, actively participating in all stages of litigation for nearly three decades. This protracted silence, coupled with their active engagement, was deemed a waiver of their right to challenge jurisdiction.

The Court stated:

It is settled that, upon the existence of certain exceptional circumstances, a party may be barred from raising lack of subject matter jurisdiction on the ground of estoppel.

The Supreme Court underscored that while jurisdictional defects are typically fundamental, the doctrine of estoppel by laches provides a crucial counterbalance to prevent abuse of the judicial process. Allowing parties to belatedly raise jurisdictional issues after years of litigation would not only prejudice the opposing party but also undermine the stability and efficiency of the judicial system. The Court refused to reward the petitioners’ inaction, emphasizing that equity, fair play, and public policy prevent the Court from entertaining their belated jurisdictional challenge.

Furthermore, the Court swiftly dismissed the petitioners’ other arguments, including defective service of summons and failure to substitute a deceased party. The Court reiterated that voluntary appearance cures defects in summons and that mere failure to substitute a deceased party does not automatically nullify a decision absent a showing of due process violation. In this case, the petitioners actively participated, negating any claim of violated due process. Finally, the Court upheld the CA’s affirmation of the RTC’s decision on the merits, finding no reversible error in declaring the Deeds of Absolute Sale void due to the lack of authority of the sellers.

In essence, this case serves as a strong reminder that while jurisdictional challenges are important, they must be raised in a timely manner. Parties cannot strategically delay such challenges to gain an advantage or to escape an unfavorable judgment after years of litigation. The doctrine of estoppel by laches ensures fairness and prevents the manipulation of jurisdictional rules to the detriment of the opposing party and the judicial system itself.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: SPS. LINO REBAMONTE V. SPS. GUILLERMO LUCERO, G.R. No. 237812, October 02, 2019