Effect of Estoppel on Objection to Jurisdiction

15. Figueroa vs. People (G.R. No. 147406, 14 July 2008)

KEY TAKE-AWAY OR DOCTRINE TO REMEMBER

The general rule should 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, 23 SCRA 29
(1968).

FACTS

Venancio Figueroa was charged and convicted by RTC Bulacan with reckless imprudence resulting in homicide. In his appeal with
CA, he questioned, among others, for the first time, the trial court’s jurisdiction. CA however considered the Figueroa to have
actively participated in the trial and to have belatedly attacked the jurisdiction of the RTC; thus, he was already estopped by laches
from asserting the trial court’s lack of jurisdiction. CA affirmed RTC’s ruling. Hence, this petition. Figueroa asserts that the lack of
jurisdiction of a court over the subject matter may be raised at any time even for the first time on appeal. As undue delay is further
absent herein, the principle of laches will not be applicable.

ISSUE/S STATUTES/ARTICLES INVOLVED

Does active participation of the petitioner in the trial of his case,

which is initiated and filed not by him but by the public
prosecutor, amount to estoppel?

HELD: NO

The general rule should 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. Indeed, the fact that a person attempts to invoke unauthorized jurisdiction of a court does not estop him from
thereafter challenging its jurisdiction over the subject matter, since such jurisdiction must arise by law and not by mere consent of
the parties. This is especially true where the person seeking to invoke unauthorized jurisdiction of the court does not thereby secure
any advantage or the adverse party does not suffer any harm.

Applying the said doctrine to the instant case, the petitioner is in no way estopped by laches in assailing the jurisdiction of the RTC,
considering that the raised the lack thereof in his appeal before the appellate court. At that time, no considerable period had yet
elapsed for laches to attach. True, delay alone, though unreasonable, will not sustain the defense of “estoppel by laches” unless it
further appears that the party, knowing his rights, has not sought to enforce them until the condition of the party pleading laches
has in good faith become so changed that he cannot be restored to his former state, if the rights be then enforced, due to loss of
evidence, change of title, intervention of equities, and other causes.

We note at this point that estoppel, being in the nature of a forfeiture, is not favored by law. It is to be applied rarely—only from
necessity, and only in extraordinary circumstances. The doctrine must be applied with great care and the equity must be strong in
its favor. When misapplied, the doctrine of estoppel may be a most effective weapon for the accomplishment of injustice. Moreover,
a judgment rendered without jurisdiction over the subject matter is void. Hence, the Revised Rules of Court provides for
remedies in attacking judgments rendered by courts or tribunals that have no jurisdiction over the concerned
cases. No laches will even attach when the judgment is null and void for want of jurisdiction.