Crisostomo v. Marquez
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership of a parcel of land in Bulacan. Initially, the Court of First Instance of Bulacan decreed the registration of the land in favor of the estate of the late Laureano Marquez. However, the heirs of Pedro Crisostomo (petitioners) sought to have the land registered in their names, claiming it as their inheritance. 2. Procedural History: Following the trial court's order dated April 26, 1960, which favored the heirs of Laureano Marquez, the Crisostomo heirs appealed to the Court of Appeals. During the appellate proceedings, the Marquez heirs moved to transfer the case to the Supreme Court, asserting that the land's value exceeded P200,000, placing it within the Supreme Court's exclusive jurisdiction. The Crisostomo heirs opposed this, arguing the valuation was inflated and citing a lower assessed value. The Court of Appeals, despite not explicitly ruling on jurisdiction, rendered a decision on the merits on November 8, 1966, upholding the trial court's judgment. The Crisostomo heirs' subsequent motions for reconsideration and extension were denied, leading to the declaration of the decision as final on December 8, 1966. 3. The Petition: The petitioners filed a petition for certiorari and mandamus with the Supreme Court, raising two main issues: (1) whether the Court of Appeals lacked jurisdiction due to the disputed land value exceeding P200,000, and (2) whether the Court of Appeals abused its discretion in denying their motion for a 30-day extension to file a memorandum and in declaring its decision final. The petitioners argued that the Court of Appeals should not have entertained the appeal given the jurisdictional amount, while previously they had actively defended the Court of Appeals' jurisdiction. They also contended that their motion for reconsideration should have suspended the finality of the decision, but the Court found their motion to be pro forma and insufficient to stay the period for appeal.
Issue(s)
Whether the Court of Appeals had jurisdiction over the appeal, considering the value of the property in controversy. Whether the Court of Appeals abused its discretion in denying the petitioners' motion for extension of time to file their memorandum and in declaring its decision final.
Ruling
The petition is denied. The Supreme Court held that petitioners are estopped from questioning the jurisdiction of the Court of Appeals, and that their motion for reconsideration was pro forma, thus not suspending the finality of the judgment.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the petitioners are estopped from questioning the jurisdiction of the Court of Appeals. The records showed that it was the petitioners themselves who urged the trial court to transmit the case to the Court of Appeals for review, thereby choosing that tribunal. They did not raise the issue of jurisdictional amount before the trial court. The Court reiterated the principle that a party cannot invoke the jurisdiction of a court to secure affirmative relief and then repudiate or question that same jurisdiction. Furthermore, when the respondents first challenged the Court of Appeals' jurisdiction, the petitioners actively defended it, even going so far as to convince the court that it had the authority to decide the appeal. Their subsequent challenge to the jurisdiction, raised for the first time before the Supreme Court, was deemed a weak attempt to replace the remedy of ordinary appeal, which had been foreclosed by the Court of Appeals' order declaring its decision final. The Court emphasized that sound public policy bars petitioners from challenging the jurisdiction after they had procured it themselves, speculating on the fortunes of litigation. On the issue of the denial of extension and finality of judgment: The Supreme Court found that the petitioners' motion for reconsideration was a "pro forma" motion. It was a one-sentence motion that did not specify the findings or conclusions in the decision that were allegedly contrary to law or evidence. Such a motion, being a "mere scrap of paper," cannot suspend the running of the period for taking an appeal. The petitioners were granted an initial extension of 15 days to file their memorandum or motion for reconsideration, which they allowed to lapse. Subsequently, they sought a further extension of 30 days, which was denied. The Court noted the long history of litigation and the petitioners' delay tactics, concluding that the denial of the extension was justified, especially considering the respondent court's manifest intention to delay the proceedings. The risk of denial for the second extension request was theirs, as they merely filed it without assurance of approval.
Main Doctrine
A party who invokes the jurisdiction of a court to secure affirmative relief and subsequently questions that same jurisdiction after obtaining or failing to obtain such relief is estopped from doing so. Furthermore, a pro forma motion for reconsideration does not suspend the running of the period for appeal.