by Abby
CORAZON JALBUENA DE LEON v. CA, GR No. 96107, 1995-06-19 (/juris/view/c809e?
user=gV1ZaSDdjQnlFUDArVFltR3UvSGRDaUdYUFduVWxoSEZ1aWJNZzI4Wk1kdz0=)
Facts:
two parcels of irrigated riceland covering an area of 117,785 square meters located in Barangays Guintas and
Bingke, Napnod, Leganes, Iloilo. Jesus Jalbuena, the owner of the land, entered into a verbal lease contract in
1970 with Uldarico Inayan, for one year renewable for the same period. Inayan, private respondent herein,
bound himself to deliver 252 cavans of palay each year as rental to be paid during the first ten days of
January. Private respondent who was a godson of Jesus
Jalbuena, was allowed to continue with the lease from year to year.
Petitioner Corazon Jalbuena de Leon is the daughter of Jesus Jalbuena and the transferee of the subject
property.
petitioner filed a complaint against private respondent before the Regional Trial Court of Iloilo City for
"Termination of Civil Law Lease; Recovery of Possession; Recovery of Unpaid Rentals and Damages."
Private respondent,... claimed that the land had been tenanted by his father since 1938 and that he has
already been issued Certificates of Land Transfer (CLT) for the subject property. These Certificates of Land
Transfer were subsequently cancelled by the then
Ministry of Agrarian Reform on November 22, 1983 upon a finding that said lands were owned by Jesus
Jalbuena and that the CLTs were erroneously issued.
the trial court's decision... in favor of petitioner De Leon... appellate court... affirmed the trial court's decision
Issues:
jurisdiction and alleged that the lower court, acting as Court of Agrarian Relations, had no jurisdiction over
the action.
Ruling:
Jurisdiction of the court over the subject matter is conferred only by the Constitution or by law.[11] It is
determinable on the basis of allegations in the complaint.[12]
An error in jurisdiction can be raised at any time and even for the first time on appeal.[13] Barring highly
meritorious and exceptional circumstances,[14] neither estoppel nor waiver may be raised as defenses to
such an... error.
A study of the complaint instituted by petitioner in the lower court reveals that the case is, contrary to the
findings of the respondent appellate court, not one of unlawful detainer.
Petitioner's complaint was for "Termination of Civil Law Lease; Recovery of Possession; Recovery of Unpaid
Rentals and Damages."[23] After alleging the facts regarding the lease of the subject property, including
Inayan's refusal to pay rent and to vacate,... petitioner prayed that the trial court declare the civil law lease
(and not "tenancy or agricultural lease") terminated. Plaintiff likewise prayed that defendant be ordered to
vacate the premises, pay back rentals, unpaid irrigation fees, moral and exemplary damages and... litigation
fees.
Not being merely a case of ejectment, the regional trial court possessed jurisdiction to try and resolve the
case.
We find that the situation in the case at bench falls within the ambit of justifiable cases where estoppel may
be applied. The trial court's recourse to agrarian procedure was undoubtedly provoked by private
respondent Inayan's insistence on the existence of a tenancy... relationship with petitioner. Private
respondent cannot now use these same misrepresentations to assert the court's lack of jurisdiction. He
cannot invoke the court's jurisdiction to secure affirmative relief against petitioner and, after failing to obtain
such... relief, repudiate or question that same jurisdiction.
Participation in judicial proceedings where the court was devoid of jurisdiction is not normally considered as
estoppel because the jurisdiction of a court is mandated by law. Estoppel is likewise not appreciated where a
mistaken belief in the court's jurisdiction is... maintained.
But private respondent's case is different for it does not involve an honest mistake. He is directly responsible
for the trial court's use of the special rules of agrarian procedure. His insistence brought about the want of
jurisdiction he conveniently asserted... before the appellate court, and only after an adverse decision was
levelled against him. Private respondent cannot be allowed to seek refuge under the protective mantle of the
law after he has abused and made a mockery of it. He is, therefore, considered estopped... from asserting the
court's want of jurisdiction to try the case.
Moreover, the case was ostensibly one that involved agrarian matters, as alleged by private respondent.
Hence the trial court cannot be faulted for its use of agrarian procedure.
Principles:
