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Question
A civil action for quieting of title and reconveyance over real property is filed in the Municipal Trial Court (MTC) by Aria against Bruno. The land is registered in Bruno’s name, and the relief sought would, if granted, affect title to real property. Bruno did not object to the MTC’s lack of subject-matter jurisdiction and fully participated in the proceedings (answered, presented evidence, and cross-examined witnesses). After trial, the MTC renders judgment in favor of Aria. Bruno then files a motion for relief, contending lack of SMJ. (a) Identify the doctrine governing the effect of estoppel on subject-matter jurisdiction. (b) Distinguish the controlling rule on estoppel in this context from the general principle that lack of SMJ cannot be cured by consent. (c) Apply the doctrine to the facts: is Bruno barred by estoppel from challenging the MTC’s lack of SMJ, and what is the proper judicial remedy if the court truly lacked SMJ?