DOCTRINE OF EQUITABLE ESTOPPEL OR ESTOPPEL BY LACHES:

       In Tijam v. Sibonghanoy (131 Phil. 556 (1968), the party-litigant actively participated in the proceedings before the lower court and filed pleadings therein. Only 15 years thereafter, and after receiving an adverse Decision on the merits from the appellate court, did the party-litigant question the lower court’s jurisdiction. Considering the unique facts in that case, the Supreme Court held that estoppel by laches had already precluded the party-litigant from raising the question of lack of jurisdiction on appeal. In Figueroa v. People, G.R. No. 147406, 14 July 2008, 558 SCRA 63, the Supreme Court cautioned that Tijam must be construed as an exception to the general rule and applied only in the most exceptional cases whose factual milieu is similar to that in the latter case.

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