Lagundi v. Bautista
REITERATIONFacts
The Antecedents: Pacita Bautista filed a complaint for "Ownership, Possession and Damages with Prayer for Preliminary Mandatory Injunction and Temporary Restraining Order" against Rosie Collantes Lagundi. Lagundi filed an Answer and an Amended Answer. Bautista later amended her complaint to "Ejectment, Quieting of Title and Damages with Prayer for Preliminary Mandatory Injunction and Temporary Restraining Order." The trial court initially denied Bautista's motion for summary judgment but later granted it on reconsideration, ordering Lagundi to vacate the property. The Court of Appeals affirmed this decision, and the Supreme Court denied Lagundi's petition for review on certiorari for being filed beyond the extended period, with the Resolution becoming final and executory. Procedural History: After the decision became final and executory, Bautista filed a Motion for the Issuance of a Writ of Execution, which the Regional Trial Court (RTC) granted. Lagundi's motion for reconsideration was denied by the RTC, which noted that the case was final and executory and the writ had been implemented. The Court of Appeals affirmed the RTC's orders, finding Lagundi estopped by laches from assailing the RTC's jurisdiction at such a late stage. The Court of Appeals noted Lagundi's active participation in the proceedings for 10 years without questioning jurisdiction, even filing a counterclaim, and only raising the issue during execution. The Petition: Lagundi filed a Petition for Review on Certiorari with the Supreme Court, assailing the Court of Appeals' decision. She argued that the Court of Appeals erred in affirming the execution because the judgment was void from the beginning due to lack of jurisdiction, as the case should have been filed with the Municipal Trial Court. She also argued that execution would be unjust and inequitable, and that she was denied due process as the summary judgment was granted without her presenting evidence. The heirs of Bautista argued for dismissal based on res judicata and the finality of the previous Supreme Court resolution.
Issue(s)
Whether petitioner Rosie Collantes Lagundi is estopped by laches from assailing the trial court's jurisdiction over the subject matter during the execution of judgment. Whether the Regional Trial Court had jurisdiction over the subject matter of the case, considering the nature of the complaint and the absence of the assessed value of the properties. Whether petitioner was denied due process.
Ruling
The Petition is DENIED. The November 15, 2012 Decision and May 3, 2013 Resolution of the Court of Appeals in CA-G.R. SP No. 114274 are AFFIRMED.
Ratio Decidendi
On the issue of estoppel by laches from assailing jurisdiction: The Supreme Court affirmed the Court of Appeals' finding that petitioner Lagundi is estopped by laches from assailing the Regional Trial Court's (RTC) jurisdiction. The Court reiterated that while jurisdiction over the subject matter is conferred by law and can generally be raised at any stage, this rule admits of exceptions based on equity and public policy, particularly in cases of estoppel by laches. Lagundi actively participated in the proceedings before the RTC and the Court of Appeals for approximately 10 years, filing responsive pleadings, seeking affirmative reliefs through counterclaims, and appealing adverse decisions. She only raised the issue of jurisdiction during the execution stage, after the judgment had become final and executory and the writ of execution had been implemented. This prolonged silence and active participation, followed by a belated challenge to jurisdiction, demonstrated a failure to exercise due diligence and an inequitable conduct that would bar her from questioning the jurisdiction at such a late hour. The Court emphasized that allowing such a challenge would render all prior proceedings useless and cause irreparable damage to the respondents who relied on the forum and Lagundi's implicit waiver of the jurisdictional defect. On the issue of RTC's jurisdiction over the subject matter: The Court found that petitioner was correct in asserting that the RTC might have lacked jurisdiction over the subject matter, not for the reason she initially invoked (forcible entry case belonging to MTC), but because the assessed value of the real properties involved was not averred in the Amended Complaint. Under Republic Act No. 7691, the jurisdiction of the RTC over actions involving title to or possession of real property, or quieting of title, depends on the assessed value of the property. Since this value was not stated, it was impossible to definitively determine which court had exclusive original jurisdiction. However, this finding did not alter the outcome because of the application of estoppel by laches. On the issue of denial of due process: The Court implicitly rejected Lagundi's claim of denial of due process. The Court noted that Lagundi actively participated in the proceedings before the lower courts, filing responsive pleadings to both the original and amended complaints, and appealing adverse decisions. This active participation indicated that she was afforded ample opportunity to present her case and was not denied due process. The fact that the trial court granted a summary judgment did not, in itself, constitute a denial of due process, especially since Lagundi had the opportunity to file responsive pleadings and participate in subsequent proceedings.
Main Doctrine
A party is estopped by laches from assailing the trial court's lack of jurisdiction over the subject matter when they actively participated in the proceedings, sought affirmative relief, and only raised the issue of jurisdiction after an adverse judgment became final and executory, especially when doing so would cause irreparable damage to the other party.