Royales v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Petitioners Apolinar R. Royales and Presentacion Gregorio were lessees of a residential house owned by respondent Jose Planas. On August 25, 1980, Planas filed an ejectment suit against petitioners before the City Court of Manila. Procedural History: After issues were joined and trial ensued, the case was submitted for decision when petitioners and their counsel failed to appear at a hearing. The City Court rendered a decision ordering the defendants to vacate the premises and pay attorney's fees and costs. After the decision became final and executory, Planas sought execution. Petitioners then filed a petition for certiorari and prohibition with the Regional Trial Court (RTC), assailing the City Court's decision for lack of jurisdiction due to failure to comply with the barangay conciliation process under P.D. 1508. The RTC declared the City Court's judgment void for lack of jurisdiction. Upon appeal, the Intermediate Appellate Court (IAC) vacated the RTC's decision, reinstating the City Court's judgment. Petitioners then filed the instant petition before the Supreme Court. The Petition: Petitioners seek to annul the IAC's decision, arguing that the City Court lacked jurisdiction for failure of respondent Planas to avail of the barangay conciliation process as required by P.D. 1508 before filing the ejectment suit.
Issue(s)
Whether the failure to comply with the barangay conciliation process under P.D. 1508 renders a court judgment void for lack of jurisdiction. Whether petitioners are estopped from questioning the jurisdiction of the City Court after voluntarily submitting to it.
Ruling
The petition is devoid of merit. The decision of the respondent Intermediate Appellate Court is affirmed.
Ratio Decidendi
On the issue of jurisdiction and compliance with P.D. 1508: The Supreme Court reiterated that in disputes covered by P.D. 1508, barangay conciliation is a pre-condition for filing an action in court. Section 6 of P.D. 1508 explicitly states that no complaint shall be filed unless there has been a confrontation before the Lupon Chairman or Pangkat, and no conciliation or settlement was reached, or the settlement was repudiated. The Court acknowledged that there was no dispute that the case was never referred to the Barangay Lupon for conciliation prior to the filing of the complaint, and respondent Planas failed to allege compliance in his complaint. Ordinarily, non-compliance with this condition precedent could make a complaint vulnerable to dismissal on grounds of lack of cause of action or prematurity. However, the Court clarified that such omission would not prevent a court of competent jurisdiction from exercising its power of adjudication over the case before it, especially when the defendants failed to object to such exercise of jurisdiction in their answer and throughout the entire proceedings. On the issue of estoppel: The Supreme Court held that petitioners are estopped from questioning the jurisdiction of the City Court. While petitioners could have prevented the trial court from exercising jurisdiction by seasonably taking exception thereto, they instead invoked the very same jurisdiction by filing an answer and seeking affirmative relief from it. Furthermore, they actively participated in the trial of the case by cross-examining the respondent. The Court emphasized that petitioners cannot belatedly adopt an inconsistent posture by attacking the jurisdiction of the court to which they had voluntarily submitted themselves. Citing Tijam vs. Sibonghanoy, the Court stated that a party cannot invoke the jurisdiction of a court to secure affirmative relief and then repudiate or question that same jurisdiction after obtaining or failing to obtain such relief. This principle is based on public policy, as it is not right for a party who has affirmed and invoked the jurisdiction of a court to secure affirmative relief to afterwards deny that same jurisdiction to escape a penalty.
Main Doctrine
A party who voluntarily submits to the jurisdiction of a court by filing an answer and participating in the proceedings cannot later question the court's jurisdiction after an adverse decision has been rendered.