GR 147406; (July, 2008) (Digest)
G.R. No. 147406 ; July 14, 2008
VENANCIO FIGUEROA y CERVANTES, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
An Information for reckless imprudence resulting in homicide was filed against petitioner Venancio Figueroa before the Regional Trial Court (RTC) of Bulacan. After trial, the RTC convicted him. On appeal before the Court of Appeals (CA), Figueroa, for the first time, questioned the RTC’s jurisdiction over the case. The CA acknowledged that under the amended Section 32(2) of B.P. Blg. 129 (by R.A. No. 7691 ), the offense, punishable by prision correccional in its medium and maximum periods (2 years, 4 months and 1 day to 6 years), fell within the exclusive original jurisdiction of the Municipal Trial Courts (MTCs). However, the CA ruled that the petitioner was estopped by laches from assailing jurisdiction, having actively participated in the four-year trial without raising the issue.
ISSUE
Whether the petitioner is estopped by laches from questioning the RTC’s lack of jurisdiction over the criminal case.
RULING
No. The Supreme Court reversed the CA and held that the petitioner was not estopped by laches. The Court clarified the doctrine of estoppel by laches in relation to jurisdiction, as first enunciated in Tijam v. Sibonghanoy. The principle applies only in exceptional circumstances where a party’s active participation and failure to question jurisdiction over an unreasonable length of time are so glaring as to constitute abandonment or waiver. The Court emphasized that jurisdiction over the subject matter is conferred by law and its absence can generally be raised at any stage. In this case, the petitioner raised the jurisdictional issue at the first opportune time—in his appeal to the CA. A four-year trial period, while not insignificant, was not deemed an unreasonable delay amounting to laches, especially since the petitioner did not initiate the case and the jurisdictional error was attributable to the public prosecutor. Consequently, the RTC decision was declared void for lack of jurisdiction. The case was remanded to the proper MTC for further proceedings, with the period during the null proceedings excluded from any prescriptive period. The ruling underscores that laches is applied cautiously to prevent a manifestly unjust outcome and not to bar a timely challenge to a court acting without authority.