Bernardo v. Villegas
REITERATIONFacts
The Antecedents: This case originated from a complaint for accion publiciana filed by the Heirs of Eusebio Villegas against Honorio Bernardo, Romeo Gaza, and Monina Francisco. The respondents claimed ownership of a parcel of land under Transfer Certificate of Title (TCT) No. 46891. They alleged that the petitioner, Bernardo, along with Gaza and Francisco, surreptitiously entered and occupied a portion of this land, constructing their houses thereon. Prior attempts at conciliation at the barangay level were unsuccessful. The respondents sought to recover possession of the property and damages. Procedural History: The respondents had previously filed an ejectment case against the petitioner and others before the Municipal Trial Court (MTC), which was dismissed due to lack of jurisdiction, having been filed beyond the one-year prescriptive period for forcible entry. Subsequently, the respondents filed the present accion publiciana case before the Regional Trial Court (RTC). The RTC ruled in favor of the respondents, ordering the petitioner and others to vacate the land and pay damages. Upon appeal, the Court of Appeals affirmed the RTC's decision. The petitioner's motion for reconsideration was denied, leading to the present petition before the Supreme Court. The Petition: This petition for review on certiorari under Rule 45 of the Rules of Court assails the Court of Appeals' decision. The petitioner primarily argues that the RTC lacked jurisdiction over the subject matter because the respondents' complaint failed to state the assessed value of the property, which is a requirement for determining jurisdiction in real actions under Batas Pambansa Blg. 129, as amended by Republic Act No. 7691. The petitioner contends that he raised this issue of jurisdiction early and should not be estopped from doing so, despite actively participating in the proceedings. The Supreme Court is asked to determine whether the petitioner is barred by estoppel from raising the issue of lack of jurisdiction.
Issue(s)
Whether the petitioner is estopped from raising the issue of lack of jurisdiction of the Regional Trial Court over the subject matter. Whether the Regional Trial Court has jurisdiction over the accion publiciana case despite the failure of the complaint to allege the assessed value of the property.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, holding that the petitioner is estopped from questioning the jurisdiction of the Regional Trial Court. The Court found that the petitioner actively participated in the proceedings before the RTC, filing pleadings and adducing evidence, and only raised the issue of jurisdiction after an adverse judgment was rendered. The Court also noted that a technical report on verification survey indicated an assessed value of ₱110,220.00, which falls within the jurisdiction of the RTC under Republic Act No. 7691.
Ratio Decidendi
On the issue of estoppel from questioning jurisdiction: The Court reiterated the general rule that jurisdiction may be questioned at any stage of the proceedings, but emphasized the exception where estoppel sets in. The Court held that a party who voluntarily submits to the jurisdiction of a court, actively participates in all stages of the case, and seeks affirmative relief cannot belatedly challenge the court's jurisdiction after an adverse judgment. The Court cited Tijam v. Sibonghanoy to underscore the inequity of allowing such a practice, which would render all prior proceedings useless. In this case, the petitioner actively participated in the RTC proceedings, filed numerous pleadings, and presented evidence, only raising the jurisdictional issue on appeal after an unfavorable decision. This conduct clearly demonstrates estoppel. On the jurisdiction of the Regional Trial Court: The Court acknowledged that the complaint failed to allege the assessed value of the property, which is determinative of jurisdiction under Batas Pambansa Bilang 129, as amended by Republic Act No. 7691. However, the Court pointed out that the Technical Report on Verification Survey, submitted as part of the records, contained a tax declaration showing an assessed value of ₱110,220.00. This assessed value clearly falls within the exclusive original jurisdiction of the Regional Trial Courts, as provided by law for real actions where the assessed value exceeds ₱20,000.00 (or ₱50,000.00 in Metro Manila). Therefore, despite the initial omission in the complaint, the RTC did possess jurisdiction over the subject matter, especially considering the petitioner's active participation and the subsequent evidence presented.
Main Doctrine
A party who actively participates in the proceedings before a lower court and submits a case for adjudication on the merits is estopped from questioning the court's jurisdiction over the subject matter, especially when the challenge is raised only after an adverse judgment is rendered.