Facts:

• Venancio Figueroa y Cervantes (petitioner) was charged with reckless imprudence resulting in homicide.
• The charge was filed on July 8, 1994, in the Regional Trial Court (RTC) of Bulacan, Branch 18, under Criminal Case No. 2235-M-94.
• The incident occurred on January 16, 1994, in Bocaue, Bulacan, where the petitioner, driving a bus, allegedly caused the death of Rodolfo Lopez y Amparado due to negligent driving.
• The RTC convicted the petitioner on August 19, 1998, sentencing him to imprisonment and ordering damages to the victim's heirs.
• The petitioner appealed to the Court of Appeals (CA), raising the issue of RTC's jurisdiction for the first time.
• The CA ruled on February 28, 2001, that the petitioner was estopped by laches due to his prior active participation in the trial.
• The CA affirmed the conviction but modified the penalty and damages.
• The petitioner filed a petition for review on certiorari, questioning the applicability of laches and the validity of the conviction.

Issue:

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Ruling:

• The Supreme Court granted the petition for review and dismissed Criminal Case No. 2235-M-94 without prejudice.
• The Court found that the petitioner was not estopped by laches in questioning the RTC's jurisdiction, as he raised the issue in his appeal without significant delay.
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Ratio:

• The Supreme Court emphasized that jurisdiction is a matter of law and cannot be conferred by consent or through estoppel.
• A lack ...continue reading