GR 124333; (March, 1997) (Digest)
G.R. No. 124333, March 26, 1997
NATIVIDAD P. ARAGON, AS REPRESENTED BY HER ATTORNEY-IN-FACT, MODESTO O. ARAGON, PETITIONER, VS. THE HONORABLE COURT OF APPEALS, AND THE MANILA BANKING CORPORATION, RESPONDENTS.
FACTS
Petitioner Natividad Aragon purchased a subdivision lot from MARENIR Development Corporation, which was mortgaged to respondent Manila Banking Corporation (MBC). After fully paying MARENIR, the latter failed to deliver the title. Aragon filed a complaint for Specific Performance against MARENIR before the Regional Trial Court (RTC), which ruled in her favor, ordering MARENIR to execute a deed of sale. The RTC later directed its branch clerk to execute the deed when MARENIR did not comply. However, the Register of Deeds refused registration because the owner’s duplicate title was held by MBC. MBC’s receiver demanded payment from Aragon to release the title, which she refused, arguing she had already paid MARENIR in full.
Aragon then filed a separate complaint against MBC in the RTC for Delivery of Title. The RTC ruled in Aragon’s favor, ordering MBC to surrender the title. On appeal, the Court of Appeals reversed the RTC, dismissing Aragon’s complaint. The CA held that the RTC in the first case (against MARENIR) lacked jurisdiction because, under PD 957, the Housing and Land Use Regulatory Board (HLURB) had exclusive jurisdiction over cases involving subdivision lot sales. Thus, the RTC’s decision against MARENIR was void, rendering the subsequent deed of sale and Aragon’s cause of action against MBC invalid.
ISSUE
Whether the Court of Appeals erred in declaring the RTC’s decision in the first case (against MARENIR) null and void for lack of jurisdiction, thereby dismissing Aragon’s complaint against MBC.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the RTC’s decision in favor of Aragon. The Court held that the CA improperly declared the RTC’s judgment in the first case void. While jurisdiction over the subject matter is conferred by law and can be raised at any stage, the attack on jurisdiction must be made within the same proceeding, not collaterally in a separate case. MBC, a stranger to the first case, cannot belatedly challenge the RTC’s jurisdiction in a different proceeding involving a different cause of action.
The Court applied the doctrine of estoppel by laches, as established in Tijam v. Sibonghanoy. MBC participated in the proceedings against it without initially questioning jurisdiction, only raising it on appeal to the CA. Allowing such a collateral attack would undermine judicial stability and public policy. The RTC validly acquired jurisdiction over the complaint against MBC for delivery of title, as it involved an action against a banking corporation holding the title, not a subdivision sale issue per se. Thus, Aragon’s right to the title, stemming from a final judgment, must be respected.