Lagundi vs. Bautista

A party who actively participates in court proceedings, seeks affirmative relief, and raises the issue of lack of jurisdiction over the subject matter only after an adverse judgment becomes final and executory is estopped by laches from assailing the court's jurisdiction. While jurisdiction over the subject matter is conferred by law and may generally be raised at any stage of the proceedings, estoppel by laches bars a party from invoking lack of jurisdiction in exceptional cases similar to the factual milieu of Tijam vs. Sibonghanoy, where the belated objection would cause irreparable damage and injustice to the party who relied on the forum and the implicit waiver.

Respondent Pacita Bautista claimed to be the registered owner of four parcels of land situated in Barangay Cabaruan, Municipality of Cauayan, Isabela, covered by Transfer Certificates of Title Nos. T-143059, T-143060, T-143058, and T-143061. Under Republic Act No. 7691, the jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts over actions involving title to or possession of real property depends on the assessed value of the property, with the threshold set at P20,000.00 (P50,000.00 in Metro Manila). The Regional Trial Courts exercise exclusive original jurisdiction over actions involving title to or possession of real property where the assessed value exceeds the threshold, and over actions incapable of pecuniary estimation.

On January 30, 1997, Pacita Bautista filed a Complaint for "Ownership, Possession and Damages with Prayer for Preliminary Mandatory Injunction and Temporary Restraining Order" before the Regional Trial Court of Cauayan City, Isabela, Branch 20, docketed as Civil Case No. Br. 20-909, claiming to be the owner of four parcels of land in Barangay Cabaruan, Cauayan, Isabela. Rosie Collantes Lagundi filed her Answer on June 10, 1997, and an Amended Answer with Counterclaim on November 12, 1997. On April 20, 1998, Bautista filed an Amended Complaint for "Ejectment, Quieting of Title and Damages with Prayer for Preliminary Mandatory Injunction and Temporary Restraining Order," to which Lagundi filed an Answer with Counterclaim on July 1, 1998.

The Amended Complaint alleged that Bautista was the registered owner and occupant of the four parcels of land covered by Transfer Certificates of Title Nos. T-143059, T-143060, T-143058, and T-143061, which were her paraphernal properties. It alleged that on January 10, 1997, the defendants, through stealth and strategy, surreptitiously entered the properties, put up a barbed wire perimeter fence, repainted the "NO TRESPASSING" prohibition to add the words "Collantes and Lagundi property," and dumped about five truckloads of gravel with the intention of putting up a structure. The Amended Complaint further alleged that on December 3, 1997, the defendants registered adverse claims on three of the titles, casting a cloud on Bautista's titles that justice demanded be removed and quieted. The Amended Complaint did not indicate the assessed value of the real properties involved.

In a June 22, 2000 Order, the trial court denied Bautista's motion for summary judgment. However, in a January 30, 2001 Decision, the trial court granted the motion for reconsideration and rendered summary judgment in favor of Bautista, ordering Lagundi to vacate the property, holding that Lagundi's mere denial of ownership was sham, pro forma, and did not raise any genuine issue as to a material fact. The Court of Appeals affirmed in a January 16, 2007 Decision. Lagundi's petition for review on certiorari before the Supreme Court was denied on July 16, 2007 for being filed beyond the extended period; the Resolution became final and executory on March 4, 2008, and an Entry of Judgment was issued.

On August 22, 2008, Bautista filed a Motion for the Issuance of a Writ of Execution, which was granted on December 11, 2009. The Writ of Execution was issued on December 18, 2009, and the Sheriff's Return dated January 5, 2010 showed it had been implemented. Lagundi filed a Motion for Reconsideration, which was denied on March 10, 2010. The Court of Appeals affirmed in a November 15, 2012 Decision, finding Lagundi estopped by laches, and denied reconsideration on May 3, 2013. Lagundi then filed the present Petition for Review on Certiorari before the Supreme Court on July 9, 2013.

• Lack of Jurisdiction: Petitioner argued that although the judgment sought to be executed attained finality, the Court of Appeals erred in affirming the execution because the judgment was void from the beginning for lack of jurisdiction, since Bautista filed a forcible entry case which should have been filed with the Municipal Trial Court at the first instance, not the Regional Trial Court.
• Injustice and Inequity: Petitioner insisted that the execution of the decision would be unjust and inequitable because of the prevailing situation of the parties, and even assuming the judgment was issued with jurisdiction, it would still be void for violating petitioner's right to due process as the motion for summary judgment was granted without petitioner being able to present evidence.
• Void Judgment: Petitioner emphasized that although the decision is final and executory, it cannot be executed since it was void for lack of jurisdiction, and even assuming the Regional Trial Court had jurisdiction, petitioner insisted on its non-implementation to prevent injustice.

• Res Judicata: Respondent's heirs argued for the outright dismissal of the petition on the ground of res judicata, since the ownership of the subject property was settled and restored to respondent through this Court's Resolution in G.R. No. 177574, which became final and executory on March 4, 2008.
• Estoppel by Laches: Respondent's heirs argued that petitioner did not question the Regional Trial Court's jurisdiction in the Answer to the Amended Complaint, even until the case reached this Court, and only when the decision's execution was imminent did petitioner belatedly object on the ground of lack of jurisdiction.
• Jurisdiction of RTC: Respondent's heirs claimed that the amended complaint was an action for quieting of title and possession, which was well within the jurisdiction of the Regional Trial Court.
• Due Process: As to petitioner's allegation of denial of due process, respondent's heirs contended that the records petitioner herself attached to the Petition reveal that she answered the complaint and amended complaint, and participated in every incident of the case before the courts.
• Mootness: Respondent's heirs claimed that the implementation of the writ of execution rendered the present case moot and academic.

• Estoppel by Laches: Whether the Court of Appeals erred in finding that petitioner is estopped by laches from assailing the trial court's jurisdiction during the execution of judgment.

• Estoppel by Laches: Yes. The Court of Appeals did not err in finding petitioner estopped by laches. While the Regional Trial Court indeed lacked jurisdiction over the subject matter because the amended complaint failed to aver the assessed value of the real properties, petitioner's 12-year delay in raising the jurisdictional challenge, her active participation in the proceedings, and her failure to offer justification for the belated objection barred her from invoking lack of jurisdiction under the exceptional circumstances of Tijam vs. Sibonghanoy.

• Estoppel by Laches: Jurisdiction over the subject matter is conferred by law and not by mere consent of the parties, and the issue may generally be raised at any stage of the proceedings and is not lost by waiver or by estoppel. However, estoppel by laches bars a party from invoking the court's lack of jurisdiction in exceptional cases similar to the factual milieu of Tijam vs. Sibonghanoy. The Court applied the six-factor test summarized in Amoguis vs. Ballado: (1) there was a statutory right in favor of the claimant; (2) the statutory right was not invoked; (3) an unreasonable length of time lapsed before the claimant raised the issue of jurisdiction; (4) the claimant actively participated in the case and sought affirmative relief from the court without jurisdiction; (5) the claimant knew or had constructive knowledge of which forum possesses subject matter jurisdiction; and (6) irreparable damage will be caused to the other party who relied on the forum and the claimant's implicit waiver.

Applying these factors, the Court found that petitioner never questioned the Regional Trial Court's jurisdiction during trial or on appeal before the Court of Appeals. She filed her Answer and Amended Answer seeking affirmative reliefs, actively participated during trial, filed an appeal before the Court of Appeals, and stayed silent on the jurisdictional issue. After this Court declared the decision final and executory due to her failure to file the appeal on time, a writ of execution was issued and implemented. It was only during the execution of the judgment, or after the lapse of 12 years from the filing of the Amended Complaint, that petitioner challenged the Regional Trial Court's jurisdiction, without offering any justification for the belated action. The Court held that to allow petitioner to question the jurisdiction of a court after seeking affirmative reliefs, actively participating in its proceedings, and only after the decision against her was rendered final and already implemented, would be the height of unfairness, inequity, and injustice to respondents—the evils which the doctrine of estoppel by laches precisely seeks to prevent.

The Court also addressed the merits of the jurisdictional question, noting that although the caption of the Amended Complaint included ejectment, it was filed on April 20, 1998, more than a year after the dispossession on January 10, 1997, so it could only be either accion publiciana or accion reivindicatoria, and an action for quieting of title, where jurisdiction depends on the assessed value of the real property. Since the Amended Complaint did not indicate the assessed value, the Regional Trial Court had no jurisdiction, following Salvador vs. Patricia, Inc. and Regalado vs. Dela Pena. However, this did not save petitioner's case because she was estopped by laches from raising the issue.

• Estoppel by Laches — Laches is the failure or neglect, for an unreasonable and unexplained length of time, to do that which, by exercising due diligence, could or should have been done earlier; it is negligence or omission to assert a right within a reasonable time, warranting a presumption that the party entitled to assert it either has abandoned it or declined to assert it. The doctrine is based on grounds of public policy which requires, for the peace of society, the discouragement of stale claims, and is principally a question of the inequity or unfairness of permitting a right or claim to be enforced or asserted. The Court applied this doctrine to bar petitioner from assailing the Regional Trial Court's lack of jurisdiction after 12 years of active participation in the proceedings and after the adverse judgment became final and executory.

• Tijam Doctrine (Estoppel by Laches in Jurisdictional Challenges) — A party may be estopped by laches from raising the issue of lack of jurisdiction over the subject matter when: (1) there was a statutory right in favor of the claimant; (2) the statutory right was not invoked; (3) an unreasonable length of time lapsed before the claimant raised the issue of jurisdiction; (4) the claimant actively participated in the case and sought affirmative relief from the court without jurisdiction; (5) the claimant knew or had constructive knowledge of which forum possesses subject matter jurisdiction; and (6) irreparable damage will be caused to the other party who relied on the forum and the claimant's implicit waiver. The edict in Tijam is not an exception to the rule on jurisdiction but a waiver or an estoppel in questioning jurisdiction when the circumstances are present.

• Jurisdiction Determined by Material Allegations of the Complaint — To determine whether a court has jurisdiction over the subject matter, the material allegations of the complaint must be examined, along with the relief sought by the party, and the law in force at the commencement of the action. Courts must apply the law on jurisdiction in relation to the allegations of ultimate facts in the complaint, regardless of whether the party is entitled to recover upon some or all of the claims asserted.

• Jurisdiction over Actions Involving Real Property — Under Republic Act No. 7691, the exclusive original jurisdiction over actions involving title to or possession of real property is determined by the assessed value of the property: Municipal Trial Courts have jurisdiction where the assessed value does not exceed P20,000.00 (P50,000.00 in Metro Manila), while Regional Trial Courts have jurisdiction where the assessed value exceeds those amounts. When the complaint fails to allege the assessed value, the court cannot determine which court has jurisdiction, and jurisdiction cannot be presumed or conferred on the court's erroneous belief that it had jurisdiction over a case.

• "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, of estoppel by deed or by record, and of estoppel by laches. Laches, in a general sense, is failure or neglect, for an unreasonable and unexplained length of time, to do that which, by exercising due diligence, could or should have been done earlier; it is negligence or omission to assert a right within a reasonable time, warranting a presumption that the party entitled to assert it either has abandoned it or declined to assert it." — This passage from Tijam vs. Sibonghanoy, quoted at length in the decision, defines the doctrine of laches and serves as the canonical formulation applied to bar petitioner's belated jurisdictional challenge.

• "The general rule should, however, be, as it has always been, that the issue of jurisdiction may be raised at any stage of the proceedings, even on appeal, and is not lost by waiver or by estoppel. Estoppel by laches, to bar a litigant from asserting the court's absence or lack of jurisdiction, only supervenes in exceptional cases similar to the factual milieu of Tijam v. Sibonghanoy." — This passage from Figueroa vs. People of the Philippines clarifies the limited scope of the Tijam exception, which the Court applied to the present case.

• "In estoppel by laches, a claimant has a right that he or she could otherwise exercise if not for his or her delay in asserting it. This delay in the exercise of the right unjustly misleads the court and the opposing party of its waiver. Thus, to claim it belatedly given the specific circumstances of the case would be unjust...[F]airness and equity must temper the parties' bravado to raise jurisdiction when they have participated in proceedings in the lower courts or when an unfavorable judgment against them has been rendered." — This passage from Amoguis vs. Ballado explains the equitable basis of estoppel by laches and why fairness and equity temper the general rule on jurisdictional challenges.

• "To allow petitioner to question the jurisdiction of a court after seeking affirmative reliefs, actively participating in its proceedings, and only after the decision against her was rendered final and already implemented, would be the height of unfairness, inequity, and injustice to respondents—the evils which the doctrine of estoppel by laches precisely seeks to prevent." — This passage states the Court's application of the doctrine to the facts of the case, articulating the ratio decidendi.

• Tijam vs. Sibonghanoy, 131 Phil. 556 (1968) — Controlling precedent establishing the doctrine of estoppel by laches in jurisdictional challenges. The Court applied its exceptional circumstances to bar petitioner's belated jurisdictional objection.

• Figueroa vs. People of the Philippines, 580 Phil. 58 (2008) — Followed; clarified that estoppel by laches only supervenes in exceptional cases similar to the factual milieu of Tijam, and that a party challenging lack of jurisdiction is not estopped where that party does not secure any advantage or the adverse party does not suffer any harm.

• Amoguis vs. Ballado, G.R. No. 189626, August 20, 2018 — Followed; summarized the six circumstances to consider in applying Tijam, which the Court adopted as the framework for determining whether estoppel by laches bars a jurisdictional challenge.

• Salvador vs. Patricia, Inc., 799 Phil. 116 (2016) — Followed; held that the Regional Trial Court could not proceed with a case for quieting of title where the complaint did not aver the assessed value of the property, as there was no basis to determine which court had jurisdiction.

• Regalado vs. Dela Pena, 822 Phil. 705 (2017) — Followed; held that courts cannot simply take judicial notice of the assessed value or market value of land, and jurisdiction cannot be presumed or conferred on the court's erroneous belief that it had jurisdiction over a case.

• Bernardo vs. Heirs of Villegas, 629 Phil. 450 (2010) — Followed; applied estoppel by laches where petitioner actively participated during trial but raised the nullity of the decision due to the complaint's omission of the assessed value only upon an adverse judgment.

• Romago, Inc. vs. Siemens Building, 617 Phil. 875 (2009) — Followed; applied the Tijam exception where petitioner actively participated in proceedings before the arbitrator but raised lack of jurisdiction only in its petition for certiorari after a writ of execution had been issued.

• Far East Bank and Trust Co. vs. Chua, 763 Phil. 289 (2015) — Followed; decreed estoppel by laches when respondent actively participated in proceedings before a commission and assailed its jurisdiction only after it ruled against it twice.

• Spouses Rebamonte vs. Spouses Lucero, G.R. No. 237812, October 2, 2019 — Followed; found the exceptional circumstances in Tijam present when petitioners failed to invoke lack of jurisdiction for 22 years despite full knowledge, participating in every stage of the proceedings.

• Section 1, Republic Act No. 7691 — Amending Batas Pambansa Blg. 129; grants Regional Trial Courts exclusive original jurisdiction over civil actions involving title to or possession of real property where the assessed value exceeds P20,000.00 (P50,000.00 in Metro Manila). Applied to determine that the Regional Trial Court lacked jurisdiction because the amended complaint failed to allege the assessed value.

• Section 3, Republic Act No. 7691 — Grants Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts exclusive original jurisdiction over cases of forcible entry and unlawful detainer, and over civil actions involving title to or possession of real property where the assessed value does not exceed P20,000.00 (P50,000.00 in Metro Manila). Applied to determine which court should have taken cognizance of the action.

• Article 476, New Civil Code of the Philippines — Cited in the amended complaint as the basis for the action for quieting of title; the provision allows a person who claims an interest in real property to bring an action to quiet title against any person who casts a cloud on that title.

• Carandang, J.
• Zalameda, J.
• Rosario, J.
• J. Lopez, J. (designated additional Member per Special Order No. 2834 dated July 15, 2021)