Amoguis v. Ballado
REITERATIONFacts
The Antecedents: The Ballado Spouses entered into contracts to sell with St. Joseph Realty for two subdivision lots. They made payments until 1979 when the collector refused to accept further payments, advising them to suspend payments and remove a caretaker's house. The Ballado Spouses complied, but payments were never resumed. In 1987, they discovered their contracts were rescinded, with notices sent to the lots' address instead of their declared residence. They attempted to pay the remaining balance, but St. Joseph Realty returned their check. Meanwhile, St. Joseph Realty sold the lots to the Amoguis Brothers, who obtained titles and occupied the properties, removing the Ballado Spouses' improvements. The Ballado Spouses filed a complaint for damages, injunction, cancellation of titles, and attorney's fees. Procedural History: The Regional Trial Court (RTC) ruled in favor of the Ballado Spouses, ordering St. Joseph Realty to accept the full payment, execute deeds of sale, pay damages, and declaring the Amoguis Brothers' titles void. St. Joseph Realty did not file an appeal brief, while the Amoguis Brothers appealed to the Court of Appeals (CA). The CA affirmed the RTC decision with modification, holding St. Joseph Realty solely liable for damages and ordering the execution of a deed of sale upon full payment of the deficiency. The CA, motu proprio, discussed the issue of jurisdiction, finding that the Housing and Land Use Regulatory Board (HLURB) had exclusive jurisdiction, but held that St. Joseph Realty and the Amoguis Brothers were estopped from raising this issue due to their active participation in the RTC proceedings. The CA also modified the RTC's finding on the Amoguis Brothers' bad faith, stating they relied on St. Joseph Realty's misrepresentation. The Amoguis Brothers' motion for reconsideration was denied. The Petition: The Amoguis Brothers filed a Petition for Review on Certiorari, raising three issues: (1) whether the RTC's lack of jurisdiction was lost by waiver or estoppel; (2) whether testimonial and documentary evidence not formally offered may be appreciated; and (3) whether they were buyers in good faith with a preferential right to the lots.
Issue(s)
Whether the Regional Trial Court's lack of jurisdiction over the subject matter was lost by waiver or estoppel. Whether testimonial and documentary evidence not formally offered may be appreciated by a trial court. Whether petitioners Gregorio Amoguis and Tito Amoguis are buyers in good faith and have preferential right to Lot Nos. 1 and 2.
Ruling
The Petition for Review is DENIED. The Court of Appeals' September 26, 2008 Decision and August 7, 2009 Resolution are AFFIRMED.
Ratio Decidendi
On the issue of jurisdiction and estoppel by laches: The Court reiterated that while jurisdiction is conferred by law and cannot be lost through waiver or estoppel, the principle enunciated in Tijam v. Sibonghanoy allows for estoppel by laches to bar a party from belatedly raising the issue of lack of jurisdiction. The Court found that the circumstances in Tijam were present in this case: a statutory right existed in favor of the claimant (jurisdiction of HLURB), this right was not invoked by the petitioners (they actively participated in the RTC proceedings), an unreasonable length of time lapsed before the issue was raised (22 years), petitioners sought affirmative relief from the RTC, they knew or should have known which forum possessed jurisdiction (PD 957 and 1344 were in effect), and irreparable damage would be caused to the respondents who relied on the implicit waiver. Therefore, petitioners were estopped from questioning the RTC's jurisdiction. On the admissibility of evidence not formally offered: The Court affirmed the CA's ruling that while evidence must be formally offered, testimonial evidence not formally offered but not timely objected to by the opposing party may still be considered. The petitioners waived their right to object by failing to do so at the earliest opportunity, thus ambushing the opposing counsel. Regarding documentary evidence, the CA correctly considered only the contracts to sell as they were the only documents attached to the written formal offer of evidence, and the failure to formally offer other documents within a considerable period after the presentation of witnesses constitutes a waiver. On whether petitioners are buyers in good faith: The Court found that the petitioners failed to discharge the burden of proving good faith. Although the CA made a conflicting finding, the RTC's finding of bad faith was supported by evidence that Francisco informed Epifanio of their claim to the properties, and despite this, petitioners continued to make improvements. The presence of existing improvements like trees and barbed wire fences, coupled with St. Joseph Realty's information about previous buyers, indicated that petitioners should have made further inquiries. The Court ruled that merely claiming to be buyers in good faith without proof is insufficient. The RTC's finding of bad faith was affirmed, and the modification by the CA regarding the liability for damages was deemed superfluous as the RTC had already ordered St. Joseph Realty to bear the damages.
Main Doctrine
While jurisdiction over the subject matter is conferred by law and cannot be lost through waiver or estoppel, a party may be barred from raising the issue of lack of jurisdiction at a belated stage if estoppel by laches has set in, particularly when the party has actively participated in the proceedings and has not raised the issue until an unfavorable judgment has been rendered, causing irreparable damage to the other party who relied on the implicit waiver.