Saturday, February 25, 2012

Figueroa vs.People

Facts: Figueroa, convicted for reckless imprudence resulting to homicide in RTC Bulacan, questioned the trial court’s jurisdiction first time on appeal before the CA. CA affirmed conviction. It said that Figueroa actively participated in RTC trial, hence, he is already estopped by laches.

Issue: Whether or not Figueroa can no longer question jurisdiction of the RTC.

Held: Yes. Jurisdiction may be questioned.

The general rule remains: a court's lack of jurisdiction may be raised at any stage of the proceedings, even on appeal. The reason is that jurisdiction is conferred by law, and lack of it affects the very authority of the court to take cognizance of and to render judgment on the action. Moreover, jurisdiction is determined by the averments of the complaint, not by the defenses contained in the answer.

Applying the said doctrine to the instant case, the petitioner is in no way estopped by laches in assailing the jurisdiction of the RTC. At that time, no considerable period had yet elapsed for laches to attach. The principle in Sibonghanoy case does not apply.

We note that estoppel, being in the nature of a forfeiture, is not favored by law. It is to be applied rarely--only from necessity, and only in extraordinary circumstances. The doctrine must be applied with great care and the equity must be strong in its favor.

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