Title
Spouses Laus vs. Optimum Security Services, Inc.
Case
G.R. No. 208343
Decision Date
Feb 3, 2016
Petitioners claimed ownership of disputed lands, alleging security guards barred entry. CA lifted WPI due to unclear prior possession but erred in dismissing the complaint. SC remanded for further proceedings.

Case Digest (G.R. No. 208343)
Expanded Legal Reasoning Model

Facts:

  • Complaint and Allegations
    • On October 3, 2005, petitioners Spouses Ceferino C. Laus and Monina P. Laus, and Spouses Antonio O. Koh and Elisa T. Koh filed Civil Case No. 12307 for “Damages with Application for a Temporary Restraining Order and Writ of Preliminary Injunction” against Optimum Security Services, Inc. (respondent), several of its security guards (including Ronnie Marivalles and Rodrigo Olivette), and TIPCO Estate Corporation (collectively, other defendants).
    • Petitioners alleged that in August 2005, armed guards employed by respondent and TIPCO prevented them from entering eight parcels of land in Mabalacat, Pampanga (TCT Nos. 576602-R; 578037-R; 578038-R; 578039-R; 575138-R; 575112-R; 576601-R; and 576603-R) which they claimed to own.
    • They prayed for moral, exemplary, and liquidated damages; issuance of a TRO and WPI directing respondents to desist from interfering with their ownership and possession; and a permanent injunction after trial.
  • Defenses and Counterclaims
    • Respondent and Marivalles contended that petitioners lacked ownership; real owners were Margarita dela Rosa, Manuel dela Pena, Michael Pineda, Fermin Dizon, William Lee, and Odon Sibug, who contracted security services through Mr. Ranilo Arceo. They asserted good faith, alleged forgery of petitioners’ deeds of sale, and noted a pending petition to cancel petitioners’ titles.
    • TIPCO denied hiring the guards or claiming possession; it disavowed any act of preventing petitioners’ entry.
  • RTC Proceedings
    • On October 6, 2010, RTC Branch 62, Angeles City granted the WPI, finding petitioners as registered owners entitled to possession and enjoined respondents from interference.
    • Respondent and TIPCO filed motions for reconsideration, denied on August 31, 2011, prompting respondent to elevate the case to the CA via a petition for certiorari and prohibition.
  • CA Proceedings
    • On March 25, 2013, the CA reversed the RTC: it lifted the WPI and dismissed petitioners’ complaint, holding that petitioners’ titles were under contest, they failed to prove prior possession, the WPI altered the status quo, and respondent was not a real party in interest.
    • The CA denied petitioners’ motion for reconsideration on July 22, 2013.

Issues:

  • Whether the CA erred in lifting the writ of preliminary injunction issued by the RTC.
  • Whether the CA erred in dismissing petitioners’ complaint for damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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