UP Law F2021 17 Figueroa v.

People
Civil Procedure Philippine Constitution 2008 Nachura, J.
Art. VIII, Secs. 1 and 2

SUMMARY
Petitioner was convicted by the RTC for reckless imprudence. In his appeal, he questioned for the first time
the jurisdiction of the trial court. The CA stated that Figueroa was already estopped by laches to question
the jurisdiction of the trial court as he had actively participated in the trial. The SC ruled in favor of
petitioner, reiterating the Calimlim doctrine, which states that lack of jurisdiction of a court may be raised at
any stage of the proceedings, even on appeal. The Sibonghanoy doctrine of estoppel by laches was stated to
be only applicable in exceptional circumstances.

FACTS

 An information for reckless imprudence resulting in homicide was filed against petitioner before the
RTC of Bulacan, Branch 18. Trial ensued and petitioner Figueroa was convicted.
 Figueroa filed an appeal before the CA. In this appeal, he questioned for the first time the jurisdiction
of the trial court. He stated that the MTC is vested with jurisdiction over all offenses punishable with
imprisonment not exceeding six years. As the penalty imposed for reckless imprudence has medium
and maximum periods of 2 years, 4 months and 1 day to 6 years, Figueroa asserted that jurisdiction
over the case should have been vested in the MTC and not the RTC.
 The CA considered Figueroa to have actively participated in the trial and to have belatedly attacked
the jurisdiction of the RTC. As such, he was already estopped by laches.
 As such, the CA affirmed his conviction, modifying only the penalty and damages.

RATIO

W/N petitioner’s failure to raise the issue of jurisdiction during the trial of the case, which was
initiated and filed by the public prosecutor before the wrong court, constitutes laches
NO. While the Solicitor General and the CA ruled that petitioner Figueroa is estopped as he had participated
actively during the pendency of the trial at the RTC- four years, Figueroa, on the other hand, is correct in
countering that the lack of jurisdiction of a court over the subject matter may be raised at any time even for
the first time on appeal. In such cases, the Court generally follows the doctrine found in Calimlim v. Ramirez,
which states that the lack of jurisdiction of a court may be raised at any stage of the proceedings, even on
appeal. Jurisdiction is conferred by law, and lack of it affects the very authority of the court to take
cognizance of and render judgment on the action.

The doctrine of Tijam v. Sibonghanoy which states that the defense of lack of jurisdiction may be waived by
estoppel through active participation in the trial is an exceptional one. Laches, or the failure or neglect to
assert a right within a reasonable time, should be clearly present to be applicable. Lack of jurisdiction must
have been raised so belatedly as to warrant the presumption that the party entitled to assert it had
abandoned or declined to assert it. In Sibonghanoy, the defense was raised in a motion to dismiss almost
fifteen years after the questioned ruling had been rendered. As such, the principle that the defense is
estopped must be applied only in cases with a factual milieu similar to Sibonghanoy. This is due to the fact
that estoppel, being in the nature of forfeiture, is not favored by law. Furthermore, a judgment rendered
without jurisdiction over the subject matter is void. No laches will even attach when the judgment is null
and void for lack of jurisdiction.

FALLO

WHEREFORE, premises considered, the petition for review on certiorari is GRANTED. Criminal Case No.
2235-M-94 is hereby DISMISSED without prejudice.

SO ORDERED.