2. Effect of Estoppel

Doctrine of Estoppel

GR: Lack of jurisdiction may be raised at any stage of the proceedings, in the trial court or on appeal. (US v. de la Santa, G.R. No. L-3181, 1907).

XPN: After voluntarily submitting a cause and encountering an adverse decision on the merits, it is too late for the losing party to question the jurisdiction of the court.

While the jurisdiction of a tribunal may be challenged at any time, sound public policy bars the petitioners from so doing after their having procured that jurisdiction themselves, speculating on the fortunes of litigation. (People v. Munar, G.R. No. L-37642, 1973).

Exceptions:

• Estoppel by laches (Tijam v. Sibonghanoy, G.R. No. L-21450, 1968)
• Estoppel by deed or estoppel in pais (Soliven v. Fastforms, G.R.No. 139031,2004)

Requisites as to the Party CLAIMING Estoppel:

• Lack of knowledge of truth as to the facts in question;
• Reliance in good faith upon the conduct or statements of the party to be estopped; and
• Action or inaction based thereon led to his detriment or prejudice (Kalalo v. Luz, G.R. No. L-27782, 1970)

ESTOPPEL against Tenant – the tenant is not permitted to deny the title of his or her landlord at the time of the commencement of their landlordtenant relationship. (See Rule 131, Sec. 2[b]) The rule on estoppel against tenants is subject to a qualification. It does not apply if the landlord’s title has expired, or has been conveyed to another, or has been defeated by a title paramount, subsequent to the commencement of lessor-lessee relationship [VII Francisco]. In other words, if there was a change in the nature of the title of the landlord during the subsistence of the lease, then the presumption does not apply. Otherwise, if the nature of the landlord’s title remains as it was during the commencement of the relation of landlord and tenant, then estoppel lies against the tenant. (Santos v. National Statistics Office, G.R. No. 171129, 2011)

CONCLUSIVE EFFECTS OF FINAL JUDGMENT — Effect of judgments or final orders. The effect of a judgment or final order rendered by a court or of the Philippines, having jurisdiction to pronounce the judgment or final order, may be as follows:

• In case of a judgment or final order against a specific thing, or in respect to the probate of a will, or the administration of the estate of a deceased person, or in respect to the personal, political, or legal condition or status of a particular person or his relationship to another, the judgment or final order is conclusive upon the title to the thing, the will or administration, or the condition, status or relationship of the person; however, the probate of a will or granting of letters of administration shall only be prima facie evidence of the death of the testator or intestate;
• In other cases, the judgment or final order is, with respect to the matter directly adjudged or as to any other matter that could have been raised in relation thereto, conclusive between the parties and their successors in interest by title subsequent to the commencement of the action or special proceeding, litigating for the same thing and under the same title and in the same capacity; and
• In any other litigation between the same parties or their successors in interest, that only is deemed to have been adjudged in a former judgment or final order which appears upon its face to have been so adjudged, or which was actually and necessarily included therein or necessary thereto. (Rule 39, Sec. 47)