Denila v.

Republic
GR No. 206077
July 15, 2020
Topic: Jurisdiction over the Issues
Doctrine: Failure to comply with any of the jurisdictional requirements for a petition for
reconstitution or other special proceedings renders the whole proceedings null and void, as it
fails to confer proper jurisdiction over the trial courts.
Facts:
The OCTs for several parcels of land owned by a Constancio and Isabel Luna was lost sometime
after the Second World War when both passed away with no direct heirs. In 2001, the Heirs of
Constancio Guzman, Inc. (HCGI), a corporation whose stakeholders were great nieces and
nephews of Constancio, filed for petitions of Reconstitution for the parcels of land, which was
denied Davao’s acting Register of Deeds for the reason that the OCTs being reconstituted were
not mutilated, destroyed nor lost but had been subject to a series of transfers. The RTC likewise
dismissed the petition for the same reason. The HCGI raised to issue to the Supreme Court for
certiorari, but was likewise denied for the disregard for the hierarchy of courts and the lack of
proof that the OCTs were destroyed or lost.
An amended reconstitution petition for the same lots was filed by petitioner Denila, who alleged
that a portion of Constancio’s estate blonged to her after a Bellie Artigas, who was entitled to
40% of the land as Constancio’s attorney-in-fact, sold her the share. The RTC granted her
petition and reconstitution was ordered.
After some time, the respondent filed for a petition of relief which was denied by the courts as
the petition had been filed 16 days after the reglementary period. The respondent then filed a
petition for certiorari with the Court of Appeals in consideration of the HCGI ruling, and the fact
that the petition for relief was valid as the days were counted from the receipt of the OSG and
not the Davao City’s Office of the City Prosecutor. The petition prospered and the Court of
Appeals ruled that the judge in the amended reconstitution case acted with grave abuse of
discretion for the misruling and the denial of the respondent’s petition for relief. The
respondent’s petition is granted and the previous decisions are voided and set aside.
The petitioner, raised to this court a petition for certiorari stating that the Court of Appeals
committed a grave abuse of discretion by reversing the RTC’s denial of the petition for relief and
that they committed an error in nullifying the granting of her reconstitution petition.
Issue
WON the RTC exceeded its jurisdiction in granting petitioner’s reconstitution petition despite
her failure to comply with some jurisdictional requirements.
Ruling
The Supreme Court reiterates that jurisdiction is the basic foundation of any judicial proceeding
as it directly relates to the power and authority such courts may hold. Without it, a judgment
rendered by courts is null and void, as a void judgment does not confer any rights or create any
obligations.
The Supreme Court discusses the aspects of jurisdiction and the source of where jurisdiction may
be found. These are, namely:
a. Jurisdiction over subject matter;
b. Jurisdiction over the parties;
c. Jurisdiction over the issues; and
d. Jurisdiction over the res or thing
Furthermore, the Supreme Court delves in the nature of special proceedings in comparison to
ordinary civil actions. Where in ordinary actions there is a definition to the parties involved, ie
the existence of a complainant which seeks the enforcement or protection of a right, parties in
special proceedings often seek to declare or make valid a status, right or fact. As such, the trial
court must have jurisdiction to take cognizance of such petition or application in compliance
with the specific procedure provided by law. The authority to proceed is conferred by a statute
which is why the manner of obtaining jurisdiction is mandatory and the same must be strictly
complied with.
Since reconstitution of a title is a special proceeding, the petitioner must first allege and prove
certain jurisdictional facts before a trial court may acquire jurisdiction. In the case at bar, the
Supreme Court finds that the petitioner was unable to strictly comply with the jurisdictional fact
requirement prescribed by law. As such, non-compliance of the same in special proceedings such
as the reconstitution, affects the trial court’s jurisdiction over the issue.
The Supreme Court denies the petition and affirms the CA ruling.
 De Joya v. Marquez
GR No. 162416
January 31, 2006
Topic: Jurisdiction over the Res
Doctrine: Jurisdiction over the res is acquired by the actual or constructive seizure by the court
of the thing in question, thus placing it in custodia legis, as in attachment or garnishment; or by
provision of law which recognizes in the court the power to deal with the property or subject
matter within its territorial jurisdiction, as in land registration proceedings or suits involving
civil status or real property in the Philippines of a non-resident defendant.
Facts
Petitioner De Joya filed for certiorari with this Court to nullify respondent judge’s
issuance of a warrant of arrest against petitioner. Petitioner argues that respondent failed to find
the existence of probable cause that justifies the warrant of arrest against him., citing Sec. 6 Rule
112 of the Revised Rules of Criminal Procedure. Petitioner also refused to submit to the Court’s
jurisdiction.
Issue
WON the warrant of arrest was valid; and
WON the petitioner may be allowed to obtain relief without submitting himself to the Court’s
jurisdiction (pertinent issue)
Ruling
The Supreme Court reiterates the requisite for the exercise of jurisdiction and how such
jurisdiction is manifested with the following:
 Jurisdiction over the plaintiff or petitioner, upon their filing of the complaint
 Jurisdiction over defendant or respondent, upon their voluntary appearance or submission
to court, or through the court’s summons
 Jurisdiction over subject matter, which is conferred by law
 Jurisdiction over the issues of the case, which are determined by the pleadings filed in the
case by the parties, or by any pre-trial stipulations.
 Jurisdiction over the res, which is acquired by actual or constructive seizure of the thing
in question, placing it in the court’s custodia legis
In the case at bar, the court has acquired jurisdiction over the res, with the thing being
petitioner’s fraudulent corporation as Sec. 133 of the Corporation Code states that a foreign
corporation may be sued and proceeded against by our courts of administrative tribunals.
Furthermore, the Supreme Court sees no exceptional reason to allow petitioner to obtain
relief without submitting himself over their jurisdiction, and given that jurisdiction over the res
had already been acquired, the petitioner’s evasive stance instead shows an intent to circumvent
and frustrate the legal process. The petition is dismissed and the warrant of arrest is upheld.
Tijam v. Sibonghanoy
GR No. L-21450
April 15, 1968
Topic: Estoppel Jurisdiction
Doctrine: Parties may be barred by laches from questioning a court’s jurisdiction over subject
matter, which are those conferred by law.
Facts
After the passing of RA No. 296 or the Judiciary Act of 1948, the petitioners, Sps. Tijam filed a
civil case against the respondents Sps. Sibonghanoy for an outstanding debt of PHP 1908. The
court issued a writ of attachment against the properties of the defendant, but was dissolved as the
respondents filed a counter-bond with Manila Surety and Fidelity Co., Inc., a non-life insurance
business. The case went to court and the CFI ruled in favor of the petitioners. A writ of execution
was issued in favor of the petitioners.
Manila Surety filed a motion to quash but was denied. 14 years later, they appealed with the
Court of Appeals, who affirmed the CFI decision. After this, Manila Surety filed a motion to
dismiss, now this time citing a lack of jurisdiction as the CFI of Cebu does not have jurisdiction
over debts that do not exceed PHP 2000, instead placing this to the jurisdiction of the lower
courts.
Issue
WON the CFI validly acquired jurisdiction over the case.
Ruling
The Supreme Court is of the opinion that the Surety is barred by estoppel by laches from
invoking their plea for the purpose of annulling their liability. As already stated, the action was
commenced in the Court of First Instance of Cebu on July 19, 1948, that is, almost fifteen years
before the Surety filed its motion to dismiss on January 12, 1963 raising the question of lack of
jurisdiction for the first time.
The Supreme Court defines laches as a general sense of failure or neglect for an unreasonable
period of time, which could have been prevented or conducted earlier had a proper sense of due
diligence been exercised. In other words, it is negligence or omission to assert a right within a
reasonable amount of time which warrants a presumption that the party entitled to the right has
abandoned or declined to assert the right.
The Supreme Court ruled that the CFI, despite not having jurisdiction as per RA No. 926,
acquired jurisdiction through estoppel of laches. The CFI ruling is affirmed and the petition is
denied.