Proclamation of Martial Law and Suspension of the Privilege of the Writ of Habeas Corpus : A Political Question in the Hands of Congress Before Becoming a Justiciable Question in the Hands of the Supreme Court?

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Limitation of the Tijam v. Sibonghanoy Doctrine (Jurisdiction Through Estoppel by Laches) : Reckless Imprudence Resulting in Homicide Case Erroneously Filed With the RTC, Figueroa vs. People, G.R. No. 147406, July 14, 2008

D E C I S I O N

(3^rd Division)

NACHURA, J.:

I.      THE FACTS

On July 8, 1994, an information for reckless imprudence resulting in homicide was filed against the petitioner before the RTC of Bulacan. Trial on the merits ensued and on August 19, 1998, the trial court convicted the petitioner as charged.

In his appeal before the CA, the petitioner questioned, among others, for the first time, the trial court's jurisdiction. The appellate court, however, in the challenged decision, considered the petitioner to have actively participated in the trial and to have belatedly attacked the jurisdiction of the RTC; thus, he was already estopped by laches from asserting the trial court's lack of jurisdiction. Finding no other ground to reverse the trial court's decision, the CA affirmed the petitioner's conviction but modified the penalty imposed and the damages awarded.