Mondejar v. Javellana
REITERATIONFacts
The Antecedents: This case stems from an auction sale of real properties owned by Dr. Oscar Broce, conducted on December 7, 1989, to satisfy a judgment rendered by the National Labor Relations Commission (NLRC) in RAB VI Case Nos. 0252-82, 0328-82, and 0329-82. The Roman Catholic Bishop of San Carlos City, Inc. (RCBSCCI) emerged as the highest bidder, and a Certificate of Sale was issued. Following the expiration of the redemption period and failure of Dr. Broce to redeem the properties, a Final Deed of Sale was executed in favor of RCBSCCI. Procedural History: On February 27, 1991, RCBSCCI, through Bishop Nicolas M. Mondejar, filed a petition with the Regional Trial Court (RTC) of San Carlos City, Branch 59, seeking the surrender of certificates of title for the auctioned properties. This petition, docketed as Cadastral Case No. RTC-280, was later amended to include other banks possessing titles. Despite receiving notice, Dr. Broce did not initially oppose the petition. Subsequently, a motion to amend the final deed of sale to correctly name RCBSCCI as the purchaser was granted. The RTC then ordered the surrender of the certificates of title. Dr. Broce moved for reconsideration, arguing he had no interest in the lots, but this was denied. The Register of Deeds canceled the original titles and issued new ones in the name of RCBSCCI. Petitioner then sought a writ of possession, which was granted, though Dr. Broce opposed it, citing a pending annulment of sale case filed by his wife. Dr. Broce appealed the writ of possession order to the Court of Appeals, which dismissed his appeal as the order was considered an execution of a final judgment. Dr. Broce's subsequent petition to the Supreme Court was rejected for procedural deficiencies. The RTC later granted further motions for the issuance of writs of possession for other properties. However, on August 9, 1993, Dr. Broce filed a motion to dismiss the case, asserting that the NLRC, not the RTC, had exclusive jurisdiction. The RTC, in an order dated February 1, 1994, granted this motion, dismissing the case for lack of jurisdiction and declaring previous RTC orders void. The motion for reconsideration was denied on August 1, 1994. The Petition: Bishop Nicolas M. Mondejar filed this petition for certiorari and mandamus seeking to annul the RTC's February 1, 1994 order dismissing Cadastral Case No. RTC-280 and the August 1, 1994 order denying his motion for reconsideration. Petitioner argues that the respondent court gravely abused its discretion by dismissing the case, contending that Dr. Broce waived his right to question the jurisdiction by actively participating in the proceedings for over two years and five months, thus being barred by estoppel and laches. Petitioner asserts that the RTC's dismissal, which nullified prior proceedings, was an inequitable act. The petition seeks to have the RTC's dismissal orders nullified and the case remanded for further proceedings.
Issue(s)
Whether the Regional Trial Court committed grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing Cadastral Case No. RTC-280 for lack of jurisdiction; and whether Dr. Oscar Broce is barred by estoppel by laches from questioning the jurisdiction of the Regional Trial Court.
Ruling
The petition is granted. The assailed orders dated February 1, 1994, and August 1, 1994, issued by the respondent Regional Trial Court are NULLIFIED. The case is REMANDED to the respondent court for further proceedings.
Ratio Decidendi
On the issue of jurisdiction and estoppel by laches: The Court acknowledged that the petition filed with the RTC was indeed an offshoot of the execution proceedings in a labor case, and ordinarily, the NLRC would have jurisdiction over such matters. The NLRC's jurisdiction extends until the highest bidder is placed in physical possession of the properties. Splitting jurisdiction is obnoxious to the orderly administration of justice, and generally, regular courts have no jurisdiction over incidents arising from the enforcement of labor decisions. However, the Court emphasized that despite the initial lack of jurisdiction, the private respondent, Dr. Oscar Broce, is now barred by the principle of estoppel by laches from impugning the RTC's jurisdiction. Dr. Broce actively participated in the proceedings before the RTC, filing motions for reconsideration and opposing the writ of possession, and even appealed to the Court of Appeals and filed a petition with the Supreme Court, all without questioning the RTC's jurisdiction over the subject matter. It was only after suffering repeated setbacks and after the execution proceedings had progressed significantly, more than two years after the case was filed, that he raised the issue of jurisdiction through a motion to dismiss. This conduct, where a party invokes the jurisdiction of a court to seek affirmative relief and then later repudiates that same jurisdiction, cannot be tolerated for reasons of public policy. The Court reiterated that a party cannot be allowed to gamble on the outcome of a case and then question the court's jurisdiction only when the judgment is adverse. To allow Dr. Broce's belated challenge would render all prior proceedings useless and compel the petitioner to start anew, which is inequitable and unfair. Therefore, the respondent court committed grave abuse of discretion in nullifying the proceedings based on a jurisdictional challenge that was barred by laches.
Main Doctrine
A party who actively participates in court proceedings and invokes the court's jurisdiction to seek affirmative relief is estopped by laches from later questioning that same jurisdiction, even if the court may have lacked jurisdiction over the subject matter from the outset. Splitting jurisdiction between labor tribunals and regular courts in execution proceedings is contrary to the orderly administration of justice.