Facts:

The case involves Venancio Figueroa y Cervantes (petitioner) against the People of the Philippines (respondent). On July 8, 1994, an information for reckless imprudence resulting in homicide was filed against the petitioner 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, as the driver of a bus, allegedly caused the death of Rodolfo Lopez y Amparado due to negligent driving. The trial commenced, and on August 19, 1998, the RTC convicted the petitioner, sentencing him to imprisonment and ordering him to pay damages to the victim's heirs.

Dissatisfied with the conviction, the petitioner appealed to the Court of Appeals (CA), where he raised, for the first time, the issue of the RTC's jurisdiction over the case. The CA, in its decision dated February 28, 2001, ruled that the petitioner was estopped by laches from questioning the RTC's jur...

Facts:

Case Background
Venancio Figueroa y Cervantes was charged with reckless imprudence resulting in homicide before the Regional Trial Court (RTC) of Bulacan, Branch 18, docketed as Criminal Case No. 2235-M-94. The case arose from a traffic incident wherein Figueroa, while driving a bus, allegedly hit and killed Rodolfo Lopez y Amparado due to negligent driving.

Trial and Conviction
After a trial on the merits, the RTC convicted Figueroa on August 19, 1998, sentencing him to imprisonment and ordering him to pay damages to the victim's heirs.

Appeal to the Court of Appeals
Figueroa appealed the decision to the Court of Appeals (CA). For the first time, he raised the issue of the RTC's lack of jurisdiction over the case. The CA, however, held that Figueroa was estopped by laches from challenging the jurisdiction because he actively participated in the trial without objecting to the RTC's authority. The CA affirmed the conviction but modified the penalty and damages awarded.

Petition to the Supreme Court
Figueroa filed a petition for review on certiorari before the Supreme Court, arguing that the RTC lacked jurisdiction over the case and that his belated challenge to jurisdiction should not be barred by laches.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction is conferred by law and cannot be waived or conferred by estoppel. The Supreme Court reiterated that jurisdiction over the subject matter is determined by law and not by the actions or consent of the parties. A court's lack of jurisdiction may be raised at any stage of the proceedings, even on appeal.

2. Estoppel by laches applies only in exceptional cases. The Court clarified that the doctrine of estoppel by laches, as established in Tijam v. Sibonghanoy, is an exception rather than the rule. It applies only when there is an unreasonable delay in raising the issue of jurisdiction, causing inequity or unfairness. In this case, the petitioner raised the issue promptly on appeal, and there was no undue delay.

3. Judgments rendered without jurisdiction are void. The Court emphasized that a judgment rendered by a court without jurisdiction is null and void. No laches can attach to a void judgment, and such a judgment is susceptible to direct and collateral attacks.

4. Active participation in trial does not automatically estop a party from challenging jurisdiction. The Court held that the petitioner's active participation in the trial does not amount to estoppel, especially since the case was initiated by the public prosecutor, not the petitioner.

5. Other issues rendered moot. Given the dismissal of the case for lack of jurisdiction, the Court found it unnecessary to address the other issues raised in the petition.

Conclusion:

The Supreme Court ruled in favor of the petitioner, dismissing the case for lack of jurisdiction and holding that the petitioner was not estopped by laches from challenging the RTC's jurisdiction. The Court reiterated the general rule that jurisdiction is conferred by law and cannot be waived or conferred by estoppel, except in exceptional cases where laches is clearly present.