Case Digest (G.R. No. 182165)
Facts:
P/Supt. Felixberto Castillo, Police Officers Romeo Bagtas, Ruperto Borlongan, Edmundo Dionisio, Ronnie Morales, Arnold Tria, and Gilberto Punzalan, Engr. Ricasol P. Millan, Engr. Redentor S. Dela Cruz, Mr. Anastacio L. Borlongan, Mr. Artemio Esguerra, "Tisoy," & John Does v. Dr. Amanda T. Cruz, Nixon T. Cruz, and Ferdinand T. Cruz, G.R. No. 182165, November 25, 2009, Supreme Court En Banc, Carpio Morales, J., writing for the Court.Respondent Amanda Cruz and her husband (the Spouses Cruz) leased a parcel in Barrio Guinhawa, Malolos, and later refused to vacate despite demands by the lessor, the Provincial Government of Bulacan (the Province). The Province sued for unlawful detainer before the Municipal Trial Court (MTC) of Bulacan; by Decision of September 5, 1997 the MTC ruled for the Province, and that judgment was affirmed by the Regional Trial Court (RTC) and became final and executory. The Spouses Cruz nonetheless resisted eviction and filed multiple actions (annulment of judgment, certiorari to the Court of Appeals, damages, injunction) many of which were dismissed, except for certain pending matters including an injunction case (Civil Case No. 833-M-2004) before RTC Branch 10 and an annulment petition before Branch 18.
On July 19, 2005, RTC Branch 10 issued what it described as a permanent writ of injunction (reinstating petition dated November 5, 2002) that effectively suspended execution pending determination of the metes and bounds of the 400-sq.-meter leased premises and remanded boundary determination to the MTC. After a geodetic engineer’s report fixed the metes and bounds, the MTC, by Order of January 2, 2008, approved the report and ruled that the RTC’s permanent injunction was ineffective; on January 21, 2008 the MTC issued a Second Alias Writ of Demolition.
The demolition was implemented on January 25, 2008; although respondents sought a temporary restraining order (TRO) from Branch 10 set for hearing that date, the demolition had already occurred earlier that day. Respondents and their family occupied the property thereafter, placing container vans and asserting ownership or possession. On February 21, 2008, petitioners — local police officers and city officials deployed pursuant to a gubernatorial memorandum instructing them to "protect, secure and maintain the possession of the property" — entered the property; respondents resisted, allegedly shoved the officers, and were arrested and charged with direct assault, trespass and light threats.
On March 3, 2008 respondents filed a "Respectful Motion‑Petition for Writ of Amparo and Habeas Data" (Special Civil Action No. 53‑M‑2008) which was raffled to Branch 10 of the RTC. The RTC, crediting respondents’ affidavits that recounted alleged threats, police deployment, and a "pitch darkness" confrontation, issued writs of amparo and habeas data by Order of March 4, 2008 and, by Decision of March 28, 2008, declared the commitment orders and waivers in the related criminal cases illegal, set them aside, and ordered the petitioners’ absolute release.
Petitioners sought relief in the Supreme Court by a petition for review under Section 19 of ...(Pro-only)
Issues:
- Did the RTC err in giving due course to respondents’ petitions for writs of amparo and habeas data where the controversy arises from a property dispute?
- Was respondents’ separate petition for the writs barred by the commencement of criminal proceedings against them (i.e., Section 22 of the Rule on the Writ of Amparo/Rule on...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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