I.

Title:

2.) Figueroa vs. People

G.R. No. 147406, July 14, 2008, Nachura, J.

II. Doctrine:
Jurisdiction over the subjectmatter in a judicial proceeding is conferred by the sovereign authority
which organizes the court; it is given only by law and in the manner prescribed by law and an objection
based on the lack of such jurisdiction can not be waived by the parties.
III. Facts:
An information for reckless imprudence resulting in homicide is filed against Venancio Figueroa
before the RTC of Bulacan. Trial on the merits ensued and he was convicted as charged.
In his appeal, petitioner questioned for the first time the jurisdiction of the RTC.
The CA acknowledged that the MTC has the jurisdiction over the case however it ruled that since
Figueroa, have actively participated in the trial for 4 years and he belatedly attacked the
jurisdiction of the RTC he was already estopped by laches from questioning the jurisdiction of the
trial court.
In his petition for certiorari, Figueroa contend that the lack of jurisdiction over the subject matter
may be raised at any time even for the first time on appeal.
IV. Issues: Whether or not a litigant may be estopped by laches from assailing the jurisdiction of a
tribunal.
V. Held:
General Rule: No, jurisdiction is not lost by waiver or by estoppel. Jurisdiction over the subjectmatter in a judicial proceeding is conferred by the sovereign authority which organizes the court; it is
given only by law and in the manner prescribed by law and an objection based on the lack of such
jurisdiction can not be waived by the parties.
Exception: A party may be barred by laches from invoking lack of jurisdiction at a late hour for the
purpose of annulling everything done in the case with the active participation of said party invoking the
plea. However, estoppel by laches only supervenes in exceptional cases similar to the factual
milieu of Tijam v. Sibonghanoy (It took 15 years before they raised the issue of jurisdiction in that
case).
Delay alone will not sustain the defense of estoppel by laches unless it appears that the party, knowing
his rights, has not sought to enforce them until the condition of the party pleading laches has in good
faith become so changed that he cannot be restored to his former state, if the rights be then enforced,
due to loss of evidence, change of title, intervention of equities, and other causes.

In this case, the petitioner is not estopped by laches in assailing the jurisdiction of the RTC,
considering that he raised the lack thereof in his appeal before the appellate court. At that time, no
considerable period had yet elapsed for laches to attach.

WHEREFORE, the petition for review on certiorari is GRANTED and the criminal case against
FIgueroa is hereby DISMISSED without prejudice.
Note: Laches, in a general sense, is failure or neglect, for an unreasonable and unexplained length of time, to do that
which, by exercising due diligence, could or should have been done earlier; it is negligence or omission to assert a
right within a reasonable time, warranting a presumption that the party entitled to assert it either has abandoned it or
declined to assert it.