G.R. No. 5649 - People vs. Samonte

Spouses Romulo and Evelyn Espiritu (petitioners) are the registered owners of an 8,268-square meter parcel of land in Barangays Bundagul and Paralayunan, Mabalacat, Pampanga, covered by Transfer Certificate of Title (TCT) No. 535706-R.
Respondents, Spouses Nicanor and Annaliza Sazon, claim to be the lawful owners of the subject land, alleging that the property was originally acquired by virtue of a sale from Spouses Modesto and Leticia Diaz and subsequently transferred through a chain of transactions.

Sps. Sazon allege that they purchased the subject land from Sps. Diaz, which was originally evidenced by TCT No. 19948/Emancipation Patent (EP) No. 413511 in the name of Modesto Diaz.
After the execution of a Deed of Absolute Sale dated December 27, 1996, Sps. Diaz surrendered physical possession and the owner’s duplicate copy of the title to Sps. Sazon.
In August 2003, Sps. Espiritu occupied and fenced the subject land, later obtaining TCT No. 535706-R after Peco, who had earlier acquired the land from Sps. Diaz, sold it to them.
Sps. Sazon challenged the validity of the titles issued to Peco and Sps. Espiritu on several grounds:

The owner’s duplicate copy of TCT No. 19948 was allegedly never surrendered or reconstituted and remained in their possession.
The necessary legal and administrative steps, such as reissuance or declaration of loss of the duplicate copy, were not carried out.
The sale in favor of Peco was disputed on the basis that Leticia Diaz had already deceased (passed away on March 17, 2001) at the time of the alleged transaction.
The transfers were argued to have been executed without the required Department of Agrarian Reform (DAR) clearance.

On October 5, 2006, Sps. Sazon filed a complaint before the Regional Trial Court (RTC) of Angeles City, Branch 57 seeking annulment of the fraudulent sales, cancellation of titles, recovery of possession, and damages, with a prayer for a writ of preliminary injunction or temporary restraining order (TRO) to prevent any acts of possession or construction on the subject land by Sps. Espiritu.
Sps. Espiritu filed an answer to dismiss the complaint, based on:

The assertion that the complaint was premised on an unregistered deed of sale, binding only between the parties and not affecting third persons or the land itself.
The argument that no specific facts were averred showing how they violated Sps. Sazon’s rights.
A claim that Sps. Diaz, not they, were the proper parties to initiate such an action.

Spouses Peco, through their representative Enrique M. Basa, argued in their answer that:

All ministerial requirements for the registration of the Deed of Absolute Sale between Peco and Sps. Espiritu had been met.
Registration of the deed carried a presumption of regularity, negating the need for a DAR clearance under the applicable administrative order.

The RTC, after a hearing on the application for a writ of preliminary injunction, issued an Order on November 11, 2009, enjoining Sps. Espiritu from committing further acts of possession or constructing any factory, warehouse, or similar buildings on the subject land. This injunction was conditioned upon Sps. Sazon posting a bond of P1,000,000.
Sps. Espiritu moved for reconsideration and for the quashing of the writ, but the RTC’s Order was sustained on August 23, 2010.
Sps. Espiritu then filed a petition for certiorari before the Court of Appeals (CA) challenging the RTC’s grant of the preliminary injunction.
In a decision dated March 5, 2012, the CA affirmed the RTC’s ruling, confirming that the trial court did not abuse its discretion in issuing the writ.

Whether the Court of Appeals committed reversible error by upholding the RTC’s issuance of a writ of preliminary injunction against Sps. Espiritu.

The central issue revolves around the discretion exercised by the RTC in granting a preliminary injunction given the evidentiary submissions from both sides.
The question also extends to whether the preliminary injunction properly preserved the status quo ante, specifically preventing acts of dominion by Sps. Espiritu, without effecting their eviction from the subject land prematurely.