DURISOL V. CA (REMEDIAL)

The RTC, formerly the CFI, is an court of general jurisdiction. All cases, the jurisdiction over which is not specifically provided for by law to be within the jurisdiction of any other court, fall under the jurisdiction of the RTC. But the RTC is also a court of limited jurisdiction over, among others, cadastral and land registration cases. All proceedings involving title to real property, or specifically land registration cases, including incidents such as the issuance or owner's duplicate certificate of title, are matters cognizable by the RTC.

It has been ruled that the RTC has jurisdiction over all actions involving possession of land, except forcible entry and unlawful detainer.

A judgment rendered by a trial court for alleged lack of jurisdiction cannot be considered void where the party who has the right to challenge it failed to do so at the first instance.

Indeed, it was only 2 decades after the institution of the case at bar, when the issue of jurisdiction was first raised. However, it is already too late since the judgment had already attained finality, considering that more than 4 years have elapsed without any action from petitioner.

Rule 47, Section 3 expressly provides that a petition for annulment of judgment based on lack of jurisdiction must be files before it is barred by laches or estoppel. Hence, it has been held that while jurisdiction over the subject matter of a case may be raised at any time of the proceedings, this rule presupposes that laches or estoppel has not supervened.