G.R. No. 207269 , July 26, 2021
ROSIE COLLANTES LAGUNDI, PETITIONER, VS. PACITA BAUTISTA, SUBSTITUTED BY HER SURVIVING CHILDREN, LINA JUDITH C. BAUTISTA, EDITH C. BAUTISTA, AND DAVID C. BAUTISTA, JR., RESPONDENTS.

FACTS

On January 30, 1997, Pacita Bautista filed a Complaint for “Ownership, Possession and Damages with Prayer for Preliminary Mandatory Injunction and Temporary Restraining Order” before the Regional Trial Court (RTC) of Cauayan City, Isabela, Branch 20. Rosie Collantes Lagundi filed an Answer and later an Amended Answer with Counterclaim. Bautista subsequently filed an Amended Complaint for “Ejectment, Quieting of Title and Damages with Prayer for Preliminary Mandatory Injunction and Temporary Restraining Order,” to which Lagundi also filed an Answer with Counterclaim. The RTC initially denied a motion for summary judgment but later granted a motion for reconsideration and rendered a summary judgment in favor of Bautista, ordering Lagundi to vacate the property. The Court of Appeals affirmed this decision. The Supreme Court denied Lagundi’s petition for review, and the judgment became final and executory. Bautista then filed a Motion for Issuance of a Writ of Execution, which the RTC granted. Lagundi filed a Motion for Reconsideration, arguing for the first time that the RTC lacked jurisdiction over the subject matter, claiming the action was for forcible entry which should have been filed with the Municipal Trial Court. The RTC denied the motion. The Court of Appeals affirmed the RTC’s orders, finding Lagundi estopped by laches from assailing jurisdiction, as she raised it only at the execution stage after actively participating in the proceedings for over a decade and after the judgment had become final.

ISSUE

Whether or not the Court of Appeals erred in finding that petitioner is estopped by laches from assailing the trial court’s jurisdiction during the execution of judgment.

RULING

The Supreme Court denied the Petition, affirming the Court of Appeals. The Court held that while jurisdiction over the subject matter is conferred by law and its lack can generally be raised at any time, a party may be estopped by laches from assailing it. Laches is the failure or neglect for an unreasonable length of time to do that which, by exercising due diligence, could or should have been done earlier. Here, Lagundi actively participated in the proceedings before the RTC for years, filing responsive pleadings, attending conferences, and appealing adverse decisions, without questioning jurisdiction. She raised the issue only after the judgment became final and executory and execution was imminent. By her conduct, she invoked the RTC’s jurisdiction and is thus estopped by laches. Furthermore, the Court noted that the amended complaint was for quieting of title and possession, an action where jurisdiction is determined by the assessed value of the property, which was within the RTC’s exclusive original jurisdiction. The Court also found no denial of due process, as Lagundi was given ample opportunity to be heard.