The Supreme Court held that a party cannot raise a jurisdictional objection for the first time on appeal if they were aware of the issue earlier and had ample opportunity to raise it. This principle, known as laches, prevents litigants from belatedly challenging a court’s jurisdiction after actively participating in proceedings and awaiting the outcome. This ruling ensures fairness and prevents parties from strategically delaying legal challenges, preserving the integrity and efficiency of the judicial process.

Lost Land, Lost Time: Can a Belated Challenge to Court Authority Save Occupants from Eviction?

The case of Delfin Lamsis, et al. v. Margarita Semon Dong-E revolves around a land dispute in Baguio City. Margarita Dong-E claimed ownership of Lot No. 1, tracing her family’s possession back to her grandfather in 1922. The Lamsis family and others occupied portions of the land, claiming permission from a third party, the Smiths. Margarita filed a complaint in the Regional Trial Court (RTC) to recover ownership and possession. After a lengthy trial, the RTC ruled in favor of Margarita, ordering the occupants to vacate the property.

On appeal, the Court of Appeals (CA) affirmed the RTC’s decision. The occupants then elevated the case to the Supreme Court, raising a new argument: that the RTC lacked jurisdiction because the Indigenous Peoples’ Rights Act (IPRA) vested original and exclusive jurisdiction over ancestral land disputes in the National Commission on Indigenous Peoples (NCIP). The central legal question became whether the occupants could belatedly challenge the RTC’s jurisdiction after years of litigation.

The Supreme Court addressed the petitioners’ claim regarding acquisitive prescription, where they asserted a right to the property based on open, continuous, and exclusive possession for over 30 years. However, the Court pointed out a critical flaw in their argument. By their own admission, their initial occupation of the land was based on the tolerance of the owner. Such permissive possession, according to established jurisprudence, does not initiate the period for acquisitive prescription unless there is an explicit repudiation of the owner’s title. This repudiation must be communicated to the owner in a clear and definitive manner.

Building on this principle, the Court noted that the petitioners failed to demonstrate any act of repudiation that would trigger the commencement of the prescriptive period. At most, the record showed that Delfin and Agustin Lamsis sold portions of the property to Maynard Mondiguing and Jose Valdez, but this occurred shortly before Margarita Dong-E initiated legal action against them. Consequently, the 30-year period required for acquisitive prescription had not been fulfilled, rendering their claim unsustainable.

The Court then tackled the issue of whether the pending application for a Certificate of Ancestral Land Title (CALT) before the NCIP should supersede the ongoing reivindicatory action in the courts. The Supreme Court clarified the nature of the NCIP proceedings. It emphasized that an application for a CALT is similar to a registration proceeding, aiming to officially recognize a pre-existing claim to ancestral land, and is an action in rem. However, the Court explicitly stated that the titling of ancestral lands does not create or vest ownership; rather, it acknowledges ownership that has already vested due to long-standing possession.

To emphasize this point, the Court quoted the case of Heirs of De Guzman Tuazon v. Court of Appeals, stating that, “ownership should not be confused with a certificate of title… A certificate of title is merely an evidence of ownership.” Therefore, questions regarding ownership must be resolved in a separate suit with a full trial where parties can present evidence. Citing another case, the Court stated, “If the [respondents] wished to assert their ownership, they should have filed a judicial action for recovery of possession and not merely to have the land registered under their respective names… Certificates of title do not establish ownership.” This crucial distinction underscores the principle that registration proceedings are not conclusive determinations of ownership.

The Court then examined the issue of whether the trial court had jurisdiction to decide the case, especially considering the enactment of the IPRA. The petitioners argued that, under the IPRA, the NCIP has jurisdiction over land disputes involving indigenous cultural communities. While it is generally true that objections to subject-matter jurisdiction can be raised at any stage, the Court invoked the doctrine of laches, as established in Tijam v. Sibonghanoy. Laches is the unreasonable delay in asserting a right, leading to the presumption that the party has abandoned it.

The Court stated that “there is laches when a party is aware, even in the early stages of the proceedings, of a possible jurisdictional objection, and has every opportunity to raise said objection, but fails to do so, even on appeal.” The Court found that the petitioners were aware of the IPRA since 1998 but failed to raise it as a ground for dismissal. Instead, they actively participated in the trial and appellate proceedings, only raising the jurisdictional issue before the Supreme Court. This delay was deemed unreasonable, and the Court held that the petitioners were barred by laches from challenging the trial court’s jurisdiction.

In essence, the Supreme Court underscored that while the IPRA does grant the NCIP jurisdiction over certain ancestral land disputes, this cannot be used as a tool for strategic delay. Litigants cannot sit on their rights and then, after years of litigation, suddenly claim that the court lacked jurisdiction all along. The Court prioritized fairness and efficiency, preventing the petitioners from disrupting the proceedings at such a late stage.

FAQs

What was the key issue in this case?	The key issue was whether the petitioners could challenge the trial court’s jurisdiction for the first time on appeal, given that they had not raised this issue earlier in the proceedings despite being aware of the relevant law.
What is laches?	Laches is the unreasonable delay in asserting a right, which can prevent a party from raising a claim or objection, even if it might otherwise be valid. The doctrine is based on fairness and prevents parties from strategically delaying legal challenges.
What is the IPRA?	The IPRA, or Indigenous Peoples’ Rights Act, is a law that recognizes and protects the rights of indigenous cultural communities to their ancestral lands and domains. It also grants the NCIP jurisdiction over certain disputes involving ancestral lands.
Does the IPRA always give the NCIP jurisdiction over land disputes involving indigenous peoples?	Not always. While the IPRA grants the NCIP jurisdiction over certain ancestral land disputes, this jurisdiction can be waived or lost if a party fails to raise the issue in a timely manner.
What is acquisitive prescription?	Acquisitive prescription is a means of acquiring ownership of property through long-term, continuous, open, and exclusive possession. However, possession based on tolerance of the owner does not start the running of the prescriptive period unless there is an explicit repudiation of the owner’s title.
What is a reivindicatory action?	A reivindicatory action is a legal action to recover ownership and possession of real property. The plaintiff must prove ownership and the right to possess the property.
What is the significance of the Deed of Quitclaim in this case?	While the petitioners attacked the validity of the Deed of Quitclaim, the Court noted that even without it, Margarita Dong-E presented sufficient evidence to prove her prior possession and ownership.
What does it mean to say that the titling of ancestral lands does not create or vest ownership?	This means that the process of obtaining a Certificate of Ancestral Land Title (CALT) does not automatically grant ownership. It merely recognizes ownership that has already been established through long-term possession and inheritance.

The Supreme Court’s decision reinforces the importance of timely asserting legal rights and objections. The doctrine of laches serves as a critical safeguard against strategic delays and ensures the efficient administration of justice. By upholding the CA’s decision, the Court has clarified the limitations on challenging jurisdiction belatedly and reaffirmed the principle that fairness and diligence are essential in legal proceedings.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: DELFIN LAMSIS, ET AL. VS. MARGARITA SEMON DONG-E, G.R. No. 173021, October 20, 2010