Jurisdiction: Correlation and Distinction of Tijam vs. Sibonghanoy, Regalario case and Fukuzume case

It is the settled rule that jurisdiction over the subject matter is conferred upon the courts exclusively by law, and as the lack of it affects the very authority of the court to take cognizance of the case, the objection may be raised at any stage of the proceedings.

It was however held in Tijam vs. Sibonghanoy that the appellants were barred by laches, considering that it took the appellants 15 years in raising the issue of jurisdiction (based on the Judicial Act of 1948) from the filing of the case(January 17, 1948) to the appeal(January 8, 1963) despite their active participation throughout the case. The same principle was cited in the case of People vs. Regalario, holding that parties are estopped from appealing a case after the reglemetary period provided by law. However, in the latter case, appeal was granted in view of the gravity of the offense and its penalty. The offense charged, having been murder, and the penalty, having been reclusion perpetua, the Supreme Court still afforded the appellants judicial review to avoid miscarriage of justice. A similar ruling to that of People vs. Regalario was held in the case of People vs. Fukuzume as opposed to the denial of the court of the appeal in the case of Tijam vs. Sibonghanoy. In People vs. Fukuzume, the Court granted the appeal of the appellant for want of jurisdiction (the proper court, having been Paranaque RTC and not Makati RTC). The court noted the distinction between the facts surrounding the case of Tijam vs. Sibonghanoy as a civil case and the facts surrounding the case of People vs. Fukuzume as a criminal case.

As a general rule, question on jurisdiction may be raised at any stage of the proceeding or on appeal (people vs. Fukuzume) but exception to the rule is when the appellant is barred by laches (Tijam vs. Sibonghanoy). But even when barred by laches, appeal may still be granted in view of the gravity of the offense and its penalty (People vs. Regalario).

In all three cases, the issue was on the timeliness of the raising of the question on jurisdiction, giving due consideration on the nature of each of the cases.

Categories: Correlation and Distinction, Criminal Procedure, Jurisdiction, People s. Regalario, People vs. Fukuzume, Tijam vs. Sibonghanoy