Facts:

The case involves Purisimo Buyco (petitioner) and Nelson Baraquia (respondent). The events unfolded in Iloilo City, where Nelson Baraquia filed a complaint against Dominico Buyco and Clemente Buyco, seeking the establishment of a permanent right of way, an injunction, and damages. Baraquia claimed that he had been using a private road on the Buycos' property to access his poultry farm from the public highway. During the proceedings, both Dominico and Clemente Buyco passed away, leading to Purisimo Buyco and his brother Gonzalo being substituted as defendants. The Regional Trial Court (RTC) of Iloilo City, Branch 39, initially granted Baraquia's application for a preliminary injunction to prevent the Buycos from closing the road. However, on February 14, 2007, the RTC dismissed Baraquia's complaint, stating that he failed to prove the essential requisites for establishing an easement of right of way as outlined in Articles 649 and 650 of the Civil Code. Consequentl...

Facts:

Parties Involved:

• Petitioner: Purisimo Buyco (substituted for Dominico Buyco and Clemente Buyco, who died during the pendency of the case).
• Respondent: Nelson Baraquia.

Background:

• Nelson Baraquia filed a complaint before the Regional Trial Court (RTC) of Iloilo City against Dominico Buyco and Clemente Buyco. The complaint sought the establishment of a permanent right of way, injunction, and damages, with a preliminary injunction and temporary restraining order. The purpose was to prevent the Buycos from closing off a private road within their property, which Baraquia had been using to access his poultry farm from the public highway.

Procedural History:

• The Buycos died during the case, and Purisimo Buyco and his brother Gonzalo were substituted as defendants.
• The RTC initially granted Baraquia's application for a preliminary injunction.
• On February 14, 2007, the trial court dismissed Baraquia's complaint, finding that he failed to establish the essential requisites for an easement of right of way under Articles 649 and 650 of the Civil Code. The court lifted the writ of preliminary injunction.
• Both parties filed notices of appeal: Baraquia appealed the dismissal of his complaint, while Purisimo Buyco filed a partial appeal regarding the non-award of damages.
• Baraquia later filed a motion to cite Purisimo Buyco and Gonzalo in contempt, alleging they had closed the road in violation of the preliminary injunction. The trial court, in a March 13, 2007 Resolution, held that the February 14, 2007 decision had not yet become final and executory, so the preliminary injunction remained valid. It declared the Buycos in contempt for closing the road on March 1, 2007.
• Purisimo Buyco moved for reconsideration, arguing that a preliminary injunction ceases to exist once quashed and that contempt cannot be declared by mere motion. The trial court, in an April 18, 2007 Resolution, set aside its March 13, 2007 ruling and granted the motion for reconsideration, holding that contempt cannot be declared by mere motion and that the validity of the preliminary injunction until finality of the decision is not firmly established in jurisprudence.

Issue:

• (Unlock)

Ruling:

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Ratio:

1. Nature of Preliminary Injunction: A writ of preliminary injunction is a provisional remedy, ancillary to the main case, and its purpose is to preserve the status quo pending the resolution of the main action. It is not a cause of action in itself and is dependent on the outcome of the main case.

2. Effect of Dismissal on Preliminary Injunction: When a complaint is dismissed, the preliminary injunction is automatically dissolved, even if the dismissal is pending appeal. The rationale is that the dismissal of the main action removes the basis for the provisional remedy.

3. Contempt Proceedings: Contempt cannot be declared by mere motion; it requires a formal charge or a verified petition. Additionally, once the main action is dismissed, the preliminary injunction ceases to exist, and any violation of it after dismissal cannot be grounds for contempt.

4. Misapplication of Lee v. Court of Appeals: The trial court's reliance on Lee v. Court of Appeals was misplaced because, in that case, the main action had not yet been decided on the merits, unlike in the present case where the complaint was dismissed.

Conclusion:

The Supreme Court ruled that the writ of preliminary injunction was automatically dissolved upon the dismissal of the complaint, and the Buycos could not be held in contempt for actions taken after the dismissal. The petition was granted, and the trial court's April 18, 2007 Resolution was reversed.