Durisol Philippines, Inc. v. Court of Appeals
REITERATIONFacts
The Antecedents: Durisol Philippines, Inc. (Durisol) obtained industrial loans from the Development Bank of the Philippines (DBP) in 1962 and 1969, securing them with a mortgage on two parcels of land. Durisol defaulted on these loans. DBP initiated extrajudicial foreclosure proceedings, emerging as the highest bidder at the sale. Durisol's president borrowed the owner's duplicate titles from DBP to obtain new titles reflecting an approved subdivision plan, promising to return them after annotation of DBP's encumbrances. However, Durisol failed to return the titles, preventing DBP from registering its ownership despite its successful foreclosure bid. Procedural History: DBP filed a petition for the surrender of the owner's duplicate titles, which the trial court granted via summary judgment. Durisol's motion for reconsideration was denied. Durisol appealed to the Intermediate Appellate Court (IAC), which remanded the case for further proceedings, finding the summary judgment improper due to genuine issues. After remand, Durisol failed to appear at a scheduled hearing, leading the trial court to allow DBP to present evidence ex parte. The trial court then issued a resolution ordering the surrender of the titles. Durisol's subsequent motion for reconsideration was denied. DBP's motion for execution was granted, and an alias writ of execution was issued. When Durisol's president refused to comply, the Register of Deeds was ordered to cancel the existing titles and issue new ones in DBP's name. DBP subsequently sold the properties to various respondents. Over four years later, Durisol filed a petition with the Court of Appeals to annul the trial court's decision and resolution, alleging lack of jurisdiction. The Court of Appeals dismissed this petition, and Durisol's subsequent motion for reconsideration was also denied. The Petition: Durisol Philippines, Inc. filed a petition for review with the Supreme Court, seeking to annul the Court of Appeals' decision that dismissed its petition for annulment of judgment. The petition raises two main issues: (1) whether the trial court lacked jurisdiction over the petition for the issuance of new duplicate owner's certificates of title, and (2) whether Durisol is estopped from challenging the court's jurisdiction. Durisol argues that the trial court lacked jurisdiction, particularly after the case was remanded by the IAC. The Supreme Court, however, noted that Durisol actively participated in the proceedings without raising the issue of jurisdiction until much later, and that the Property Registration Decree (PD 1529) conferred jurisdiction on regional trial courts for such matters. The Court also emphasized that the principle of estoppel bars a party from challenging jurisdiction after submitting to the court's authority and only raising the issue when the judgment is adverse.
Issue(s)
Whether or not the trial court had jurisdiction over the petition for issuance of new duplicate owner's certificate of title. Whether or not petitioner was estopped from challenging the court's lack of jurisdiction.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed in toto.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the Regional Trial Court (RTC), formerly the Court of First Instance (CFI), has jurisdiction over proceedings involving the issuance of owner's duplicate certificates of title under Section 107 of the Property Registration Decree (PD 1529). This section allows a party in interest to file a petition to compel the surrender of a duplicate title when it is necessary to issue a new certificate due to an involuntary instrument or the refusal of the holder to surrender the duplicate. The RTC, as a court of general jurisdiction, is vested with the authority to hear and decide such cases, especially after the effectivity of PD 1529, which consolidated land registration and related proceedings within the RTCs. The RTC's jurisdiction in land registration matters is not limited to original applications but extends to all petitions filed after the original registration of title. On the issue of estoppel: The Court ruled that petitioner was estopped from raising the issue of lack of jurisdiction. Petitioner actively participated in the proceedings before the trial court and the appellate courts without raising this defense. It failed to raise the issue in its answer to DBP's petition, in its motion to dismiss, or in its motion for reconsideration of the trial court's order. The defense of lack of jurisdiction was only raised two decades after the institution of the case, long after the judgment had attained finality. The Court reiterated the principle that a party cannot submit a case for decision, accept a favorable judgment, and then attack it for lack of jurisdiction when it becomes adverse. This undesirable practice is barred by laches and estoppel. The rule that jurisdiction may be raised at any time is subject to the supervention of laches or estoppel.
Main Doctrine
A party who actively participates in the proceedings and fails to raise the issue of lack of jurisdiction at the earliest opportunity is estopped from assailing a judgment on that ground, especially when the judgment has already attained finality and the challenge is raised after an unreasonable delay.