FIGUEROA V. PEOPLE (CIVIL)

The Court, wavered on when to apply the exceptional circumstance in Sibonghanoy and on when to apply the general rule enunciated as early as in De La Santa and expounded at length in Calimlim. The general rule should however be, as it has always been, that the issue of jurisdiction may be raised at any stage of the proceedings, even on appeal and is not lost by waiver or by estoppel. ESTOPPEL BY LACHES, to bar a litigant from asserting the court's absence or lack of jurisdiction, only supervenes in exceptional cases similar to the factual milieu of Tijam v. Sibonghanoy.

Indeed, the fact that a person attempts to invoke unauthorized jurisdiction over the subject matter, since such jurisdiction must arise by law and not by mere consent of the parties. This is especially true where the person seeking to invoke unauthorized jurisdiction of the court does not thereby secure any advantage or the adverse party does not duffer any harm.

Applying the said doctrine to the instant case, the petitioner is in no way estopped by laches in assailing the jurisdiction of the RTC, considering that he raised the lack thereof in his appeal before the appellate court. At that time, no considerable period had yet elapsed for laches to attach. True, delay alone, though unreasonable, will not sustain the defense of estoppel by laches unless it further appears that the party, knowing his rights, has not sought to enforce them until the condition of the party pleading laches has in good faith become so changed that he cannot be restored to his former state, if the rights be then enforces, due to loss of evidence, change of title, intervention of equities, and other causes. In applying the principle of estoppel by laches in the exceptional case of Sibonghanoy, the Court therein considered the patent and revolting inequity and unfairness of having the judgment creditors go up their Cavalry once more after more or less 15 years. The same, however, does not obtain in this instant case.

We note at this point that estoppel, being in the nature of a forfeiture, is not favored by law. It is to be applied rarely - only from necessity, and only in extraordinary circumstances. The doctrine must be applied with great case and the equity must be strong in its favor. When misapplied, the doctrine of estoppel may be a most effective weapon for the accomplishment of injustice. Moreover, a judgment rendered without jurisdiction over the subject matter is void. Hence, the Revised Rules of Court provides for remedies in attacking judgments rendered by courts or tribunals that have no jurisdiction is null an void for want of jurisdiction.

METROBANK V. CA (REMEDIAL)

Petitioner Metrobank is estopped from refusing the discharge of the real estate mortgage on the claim that the subject property still secures other unliquidated past due loans.

Respondent GTP, requested from Metrobank that it be furnished a copy of the full indebtedness secured by the real estate mortgage. In response thereto, Metrobank issued a statement of account which amount was immediately settled and paid the next day.

Metrobank is thus barred from taking a stand inconsistent with its representation upon which respondent GTP, as an innocent third person to the real mortgage agreement, place exclusive reliance.

For an admission or representation is rendered conclusive upon the person making it, and cannot be denied or disproved as against a person relying thereon.

It is a well-settled rule that when the evidence tends to prove a material fact which imposes a liability on a party, and he has it in his power to produce evidence which from its very nature must overthrow the case made against him it is not founded on fact, and he refuses to produce such evidence, the presumption arises that the evidence is produced would operate to his prejudice and support the case of his adversary.

No rule of law is better settled than that a party having it in his power to prove a fact, if it exists, which if proved, would benefit him, his failure to prove it must be taken as conclusive that the fact does not exist.


Where facts are in evidence affording legitimate inferences going to establish the ultimate fact that the evidence is designed to prove, and the party to be affected by the proof, with an opportunity to do so, fails to deny or explain them, they may well be taken as admitted with all the effect of the inferences afforded.

The ordinary rule is that one who has knowledge peculiarly within his own control, and refuses to divulge it, cannot complain if the court puts the most unfavorable construction upon his silence, and infers that a disclosure would have shown the fact to be as claimed by the opposing party.

Verily, Metrobank's omission to present its evidence only created an adverse inference against its cause. Therefore, it cannot now be heard to complain since CA extended a reasonable opportunity to Metrobank that it did not avail.

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.