In a significant ruling, the Supreme Court held that a party’s prolonged delay in questioning a court’s jurisdiction can bar them from raising the issue later due to the principle of estoppel by laches. This means that if a party actively participates in a case for an extended period without objecting to the court’s authority, they cannot later claim the court lacked jurisdiction, especially after an unfavorable decision. This decision underscores the importance of promptly raising jurisdictional issues and the consequences of prolonged inaction in legal proceedings, balancing the need for correct jurisdiction with the principles of fairness and judicial efficiency.

From Land Dispute to Jurisdictional Challenge: Can Decades of Participation Be Overlooked?

This case revolves around a dispute over land ownership that began in the 1990s. Spouses Guillermo and Genoveva Lucero filed a complaint in the Regional Trial Court (RTC) to recover real estate property from Spouses Lino and Teresita Rebamonte. The Rebamontes, for almost three decades of active litigation, only questioned the RTC’s jurisdiction before the Supreme Court, claiming the Municipal Trial Court (MTC) should have originally heard the case based on the property’s assessed value. The Supreme Court had to determine whether the Rebamontes’ long-standing participation in the case without raising jurisdictional concerns prevented them from challenging the RTC’s authority at this late stage.

The central legal issue hinged on whether the doctrine of estoppel by laches applied. This doctrine, rooted in equity, prevents a party from asserting a right after an unreasonable delay that prejudices the opposing party. The Supreme Court, in analyzing this issue, referenced the landmark case of Tijam v. Sibonghanoy, which established that a party could be barred from raising lack of subject matter jurisdiction if they actively participated in the proceedings and only raised the issue after an adverse decision. The Court emphasized that the principle in Tijam is applied as a waiver of a party’s right to question jurisdiction based on the doctrine of equity.

The petitioners, the Rebamontes, argued that the RTC lacked jurisdiction because the assessed value of the land in question fell below the jurisdictional threshold for RTCs, as defined by Batas Pambansa Blg. 129 (BP 129), the Judiciary Reorganization Act of 1980, as amended by Republic Act No. (RA) 7691. According to Section 33(3) of BP 129 as amended, the Municipal Trial Court (MTC) has exclusive original jurisdiction in civil actions involving title to real property located outside Metro Manila when the assessed value does not exceed P20,000.00. The respondents, the Luceros, stated in their Complaint that Lot No. 1305-A has a total market assessed value of P11,120.00. This placed the action under the jurisdiction of the MTC.

However, the Supreme Court pointed out that while the RTC indeed lacked original jurisdiction, the Rebamontes were estopped from raising this issue due to their prolonged participation in the case without objection. The Court found that the Rebamontes had actively participated in the proceedings for nearly three decades, filing answers, amended answers, a counterclaim, and motions for reconsideration, and appealing to the Court of Appeals without ever questioning the RTC’s jurisdiction. This lengthy participation, coupled with their failure to raise the jurisdictional issue earlier, led the Court to apply the doctrine of estoppel by laches.

To further elaborate, the Court stated that failure to object to jurisdiction is equivalent to invocation of that jurisdiction. As cited in the case:

As held in another case, the Court explained that the active participation of the party against whom the action is brought, coupled with his failure to object to the jurisdiction of the court or administrative body where the action is pending, is tantamount to an invocation of that jurisdiction and a willingness to abide by the resolution of the case and will bar said party from later on impugning the court or body’s jurisdiction.^[28]

The Court distinguished this case from situations where a party promptly raises jurisdictional concerns. It emphasized that the Rebamontes’ delay was not only unreasonable but also prejudicial to the Luceros, who had invested considerable time and resources in litigating the case in the RTC. The Supreme Court refused to reward the Rebamontes’ lethargy and ineptitude.

Additionally, the Rebamontes raised issues regarding defective service of summons and the failure to substitute a deceased party (Guillermo Lucero) in the case. The Court dismissed these arguments, citing Rule 14, Section 20 of the Rules of Court, which states that a defendant’s voluntary appearance in an action is equivalent to service of summons. Since the Rebamontes had actively participated in the proceedings, they could not claim a violation of their right to due process due to alleged defective service of summons. The court reasoned that the essence of due process is the reasonable opportunity to be heard and submit any evidence available in support of one’s defense. Since the Sps. Lucero were fully able to participate and present their evidence during trial, there was no violation of due process.

Regarding the failure to substitute Guillermo Lucero, the Court noted that this issue was raised for the first time on appeal and was therefore barred by estoppel. Furthermore, the Court stated that mere failure to substitute a deceased party is not sufficient ground to nullify a trial court’s decision, but rather the party alleging nullity must prove that there was an undeniable violation of due process. In this case, no undeniable violation of due process has been proven, so the argument lacks merit.

Ultimately, the Supreme Court found no reversible error on the part of the Court of Appeals and affirmed its decision. The Court upheld the RTC’s factual findings that the deeds of absolute sale executed by Josefina and Agripina Lucero in favor of Lino Rebamonte were null and void, as Josefina and Agripina lacked the legal capacity to transfer any portion of Lot No. 1305-A. As correctly held by the RTC and CA, Josefina and Agripina did not have any legal capacity to enter and to give consent to the transfer of any portion of Lot No. 1305-A.^[38]

FAQs

What is estoppel by laches?	Estoppel by laches prevents a party from asserting a right after an unreasonable delay that prejudices the opposing party. It is based on equity and fairness, preventing parties from taking advantage of their own inaction to the detriment of others.
What was the key issue in this case?	The central issue was whether the petitioners could challenge the RTC’s jurisdiction after actively participating in the case for nearly three decades without raising any objections. The Supreme Court considered the doctrine of estoppel by laches.
Why did the Supreme Court invoke estoppel by laches?	The Court invoked estoppel by laches because the petitioners had actively participated in the proceedings for an extended period without questioning the RTC’s jurisdiction. This delay prejudiced the respondents, who had invested considerable time and resources in litigating the case.
What is the significance of Tijam v. Sibonghanoy in this case?	Tijam v. Sibonghanoy is a landmark case that established the principle that a party can be barred from raising lack of subject matter jurisdiction if they actively participated in the proceedings and only raised the issue after an adverse decision. This case served as a precedent for the Supreme Court’s decision in the Rebamonte case.
What is the difference between Regional Trial Court and a Municipal Trial Court?	The Regional Trial Court (RTC) and Municipal Trial Court (MTC) differ primarily in their jurisdictional scope. RTCs handle cases involving larger sums or more serious issues, while MTCs typically deal with smaller claims and less severe offenses, as defined by law.
What did the petitioners argue regarding the service of summons?	The petitioners argued that there was defective service of summons, claiming that the RTC did not acquire jurisdiction over their person. However, the Court pointed out that their voluntary appearance and active participation in the proceedings waived any defects in the service of summons.
What did the petitioners argue regarding the failure to substitute a deceased party?	The petitioners argued that the failure to substitute Guillermo Lucero after his death rendered the RTC’s decision null and void. The Court rejected this argument, stating that mere failure to substitute a deceased party is not sufficient to nullify a decision unless it violates due process.
What was the final ruling of the Supreme Court?	The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court upheld the RTC’s factual findings and ruled that the petitioners were estopped from questioning the RTC’s jurisdiction due to their prolonged participation in the case.

This case serves as a reminder of the importance of promptly raising jurisdictional issues in legal proceedings. Parties cannot sit idly by and participate in a case for an extended period, only to challenge the court’s authority after an unfavorable decision. The doctrine of estoppel by laches ensures fairness and prevents parties from abusing the judicial 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. LINO REBAMONTE v. SPS. GUILLERMO LUCERO, G.R. No. 237812, October 02, 2019