In In Re Marriage of Ben-Yehoshua (1979) 91 Cal. App. 3d 259, husband who appeared generally and stipulated to jurisdiction over child custody was not precluded from challenging jurisdiction on appeal.) Objections to the trial court's subject matter jurisdiction over child custody matters are not waived by failure to assert them in the first instance. (Ibid.) Jurisdiction to handle a dissolution of marriage action does not necessarily include jurisdiction to resolve custody issues. ( Id. at p. 264.) In Ben-Yehoshua, the husband, wife, and their children were living in Israel. Wife returns to the United States with the children, ostensibly to visit her mother. Fourteen days after arriving in the United States, wife files for dissolution of marriage and seeks a custody order. Husband made a general appearance in the action and stipulated to the California court's jurisdiction to decide child custody matters. After the trial court awarded custody to wife, husband appealed challenging the subject matter jurisdiction of the court over child custody. This court concluded that husband could challenge the jurisdiction of the trial court to determine child custody issues because subject matter jurisdiction could not be conferred by waiver, consent, or estoppel. (In re Marriage of Ben-Yehoshua, supra, 91 Cal. App. 3d at pp. 262-263.)