The Supreme Court held that a party who actively participates in a court case and invokes the court’s jurisdiction is estopped from later challenging that jurisdiction, especially if the court’s decision is unfavorable. This ruling prevents parties from manipulating the legal system by only accepting judgments that benefit them, reinforcing the principle that one cannot approbate and reprobate.

Switching Lots, Switching Stances: Can Gonzaga Challenge the Court After Losing?

Spouses Rene and Lerio Gonzaga purchased a lot from Lucky Homes, Inc. However, due to a mistake, they built their house on the wrong lot. When they later faced foreclosure on the originally purchased lot and their attempt to swap lots failed, they sued Lucky Homes for reformation of contract. The trial court dismissed their case. Only after the court ruled against them did the Gonzagas argue that the trial court lacked jurisdiction, claiming the Housing and Land Use Regulatory Board (HLURB) should have heard the case. This raised the question: can a party who initially sought a court’s intervention later challenge its jurisdiction when the outcome is not in their favor?

The Supreme Court addressed the issue of whether the Court of Appeals erred in applying the principle of estoppel to bar the petitioners from questioning the jurisdiction of the Regional Trial Court (RTC). The petitioners contended that recent decisions of the Supreme Court had abandoned the doctrine laid down in Tijam vs. Sibonghanoy. However, the Court clarified that the doctrine of jurisdictional estoppel remains valid. This principle holds that while a decision rendered without jurisdiction is a nullity, a party’s active participation in the proceedings bars them from later challenging the court’s jurisdiction. As the Court emphasized, the essence of this doctrine is to prevent parties from abusing the judicial process by taking inconsistent positions.

The Court reiterated that a party cannot invoke a court’s jurisdiction to seek affirmative relief and then, after failing to obtain such relief, repudiate that same jurisdiction. The critical point is not whether the court initially had jurisdiction but whether the party’s conduct throughout the proceedings prevents them from challenging it later. As articulated in Tijam vs. Sibonghanoy:

“A party may be estopped or barred from raising a question in different ways and for different reasons. Thus we speak of estoppel in pais, or estoppel by deed or by record, and of estoppel by laches.”

x x x         x x x         x x x

“It has been held that a party cannot invoke the jurisdiction of a court to secure affirmative relief against his opponent and, after obtaining or failing to obtain such relief, repudiate, or question that same jurisdiction x x x x [T]he question whether the court had jurisdiction either of the subject matter of the action or of the parties was not important in such cases because the party is barred from such conduct not because the judgment or order of the court is valid and conclusive as an adjudication, but for the reason that such a practice can not be tolerated — obviously for reasons of public policy.”

Building on this principle, the Supreme Court pointed to the petitioners’ actions as demonstrative of their consent to the RTC’s jurisdiction. The Gonzagas themselves initiated the action for reformation of contract in the RTC. Throughout the proceedings, they actively participated without ever questioning the court’s authority. It was only after the RTC ruled against them and issued a writ of execution that they raised the jurisdictional issue, and only because the decision was unfavorable.

This approach contrasts with a scenario where a party raises a jurisdictional objection at the earliest opportunity. Had the Gonzagas questioned the RTC’s jurisdiction from the outset, the legal landscape would have been different. Instead, they willingly submitted to the court’s authority, only to challenge it when the outcome did not favor them.

The Supreme Court emphasized that it frowns upon parties who submit their case for decision and then accept the judgment only if it is favorable, attacking it for lack of jurisdiction if not. This practice undermines the integrity of the judicial system. Public policy dictates that courts must condemn such double-dealing, where parties deliberately take inconsistent positions, disregarding the principles of justice and good faith. The Court, in essence, highlighted the importance of consistently respecting the judicial process and not strategically manipulating it for personal gain.

FAQs

The Supreme Court’s decision in this case serves as a reminder that parties must act consistently and in good faith when dealing with the courts. By actively participating in a case and invoking a court’s jurisdiction, a party implicitly acknowledges that jurisdiction and cannot later challenge it simply because the outcome is not to their liking. This ruling reinforces the importance of respecting the judicial process and avoiding manipulative tactics that undermine the integrity of the system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.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. RENE GONZAGA AND LERIO GONZAGA vs. HON. COURT OF APPEALS, G.R. No. 144025, December 27, 2002