Amigo v. Court of Appeals

G.R. No. 102833 (February 9, 1996)

Facts:

Petitioners Lolita Amigo and Estelita Vda. de Salinas entered into a lease agreement in 1961 with Mercedes Inigo for a parcel of land known as Lot 502-C-9, located in Davao City. They constructed houses on this lot. Subsequently, Inigo sold the property to Juan Bosquit and Jesus Wee Eng, leading to the issuance of a new title (TCT No. 13659) in their names. On December 17, 1966, Bosquit and Wee exchanged a portion of Lot 502-C-9 with the City Government of Davao, which was approved by the City Council. This exchange resulted in the subdivision of the property and the issuance of new titles, including TCT No. 46656 for the city and TCT No. 46657 for Bosquit and Wee.

In 1969, Bosquit and Wee filed an unlawful detainer action against the petitioners, which was dismissed in 1976 due to a technicality regarding the notice period. Later, on October 25, 1976, Bosquit sold his interests in the property to Wee, who then filed a complaint for recovery of the property against the petitioners in 1977. The trial court appointed a geodetic engineer to survey the property, revealing that a significant portion of the petitioners' houses encroached on Lot 502-C-9-B, owned by Wee.

The trial court ruled in favor of Wee, ordering the petitioners to vacate the property and demolish parts of their houses that constituted a nuisance. The petitioners appealed the decision, but their appeal was dismissed for failure to file a brief. Wee subsequently moved for execution of the judgment, which the trial court granted. The petitioners then filed a petition with the Court of Appeals to annul the trial court's decision and subsequent orders, claiming the judgment was void due to lack of jurisdiction.

Legal Issues:

1. Did the trial court acquire jurisdiction over the subject matter and the persons of the petitioners?
2. Did the Court of Appeals err in not considering alleged badges of fraud in the exchange of lots between Wee and the City Government?
3. Were the petitioners' rights as lessees affected by the exchange of lots?
4. Are the petitioners entitled to a "right of first refusal" under Section 6 of P.D. No. 1417, preventing their eviction?

Arguments:

• Petitioners' Arguments:

  • The trial court lacked jurisdiction over the subject matter and their persons, rendering the judgment void.
  • The exchange of lots between Wee and the City Government involved badges of fraud that should have been considered.
  • Their status as lessees was not affected by the exchange, and they claimed a right of first refusal under the law.

• Respondent's Arguments:

  • The trial court had jurisdiction over the action for recovery of real property, which is within the jurisdiction of the Regional Trial Court.
  • The petitioners had voluntarily appeared in court by filing their answers, thus waiving any objection to jurisdiction over their persons.
  • The evidence supported that Wee was the registered owner of the property, and the petitioners' claims regarding the exchange and their rights as lessees were unfounded.

Court's Decision and Legal Reasoning:

The Supreme Court denied the petition for review, affirming the decision of the Court of Appeals. The Court emphasized that the petitioners' claims regarding the trial court's jurisdiction were unfounded. It reiterated that jurisdiction over the subject matter is determined by the allegations in the complaint, and the action for recovery of real property was clearly within the jurisdiction of the Regional Trial Court.

The Court also noted that the petitioners had effectively submitted to the court's jurisdiction by filing their answers and did not raise the issue of jurisdiction over their persons until after the judgment was rendered. The Court highlighted that jurisdiction over the person must be raised seasonably, and the petitioners' failure to do so barred them from contesting it at a later stage.

The Court dismissed the petitioners' arguments regarding badges of fraud and their rights as lessees, stating that these issues were not relevant to the jurisdictional question at hand. The Court underscored the importance of finality in judgments and the need to avoid reopening settled matters.

Significant Legal Principles Established:

1. Jurisdiction over the subject matter is conferred by law and determined by the allegations in the complaint.
2. A party's voluntary appearance in court constitutes a waiver of any objection to the court's jurisdiction over their person.
3. The issue of jurisdiction over the person must be raised at the earliest opportunity; failure to do so precludes later challenges.
4. Final judgments should not be reopened without compelling reasons, as this undermines the stability of judicial decisions.