GR 144817; (March, 2002) (Digest)
G.R. No. 144817. March 7, 2002.
JOSE OCA, ISABELO OCA, RODOLFO O. GUTLAY, and JOSE ABRAZALDO, petitioners, vs. COURT OF APPEALS and SERGIO O. ABALOS, respondents.
FACTS
Respondent Sergio Abalos filed a complaint for peaceful possession, leasehold, and damages with the DARAB Provincial Adjudicator, claiming to be a share-tenant-caretaker of four fishpond properties owned or leased by petitioners Jose and Isabelo Oca. He alleged a sharing arrangement where all bangus produced belonged to the petitioners, while he received sari-sari fish. He claimed petitioners ousted him in May 1992 after he requested his harvest share. Petitioners, in their Answer, denied Abalos was a tenant, asserting they were the cultivators who only hired laborers. They acknowledged a past industrial partnership with Abalos on one property but claimed he waived his rights for P140,000. They prayed for dismissal and damages via a counterclaim.
The Provincial Adjudicator declared Abalos a bona fide tenant, an order made permanent by the DARAB. The Court of Appeals modified the ruling, declaring Abalos a tenant only for the properties exclusively owned by Jose Oca and co-owned by the Oca brothers, excluding the “Salayog” property where his interest was deemed waived. Petitioners then elevated the case to the Supreme Court.
ISSUE
May petitioners belatedly raise the issue of the DARAB’s jurisdiction over the fishpond dispute for the first time at the Supreme Court?
RULING
No. The Supreme Court denied the petition, ruling that petitioners are estopped from challenging jurisdiction. The well-settled doctrine is that while jurisdiction over the subject matter is conferred by law and cannot be waived, a party may be barred from raising it on grounds of estoppel. Petitioners actively participated in the proceedings before the Provincial Adjudicator by filing an Answer with a counterclaim for damages, thereby invoking the tribunal’s authority to grant them affirmative relief. Having voluntarily submitted to its jurisdiction and sought its judgment, they cannot repudiate it after receiving an unfavorable decision.
This principle, established in Tijam v. Sibonghanoy, is grounded on public policy to prevent parties from trifling with judicial processes. The Court emphasized that allowing a jurisdictional challenge at this final stage would nullify all prior proceedings, wasting time and resources, and would be especially oppressive to the respondent tenant. Petitioners’ shift to a purely jurisdictional attack, without assailing the merits of the factual findings affirming a tenancy relationship, was deemed a dilatory tactic. Thus, the assailed Court of Appeals Decision was upheld.