G.R. No. 158836 - Sunrise Garden Corp. vs. Court of Appeals

In 1998, the Sangguniang Panlungsod of Antipolo City enacted City Ordinance No. 08-98 to create a technical committee for a feasibility study, preliminary survey, and parcellary survey for a proposed city road connecting Barangays Cupang, Mayamot, Mabugan, and Munting Dilao.
In 1999, based on a request from the Sangguniang Barangay of Cupang, the city approved the construction of the road via Resolution Big. 027-99.
The technical committee posted notices to all property owners who would be affected by the road construction, ensuring public awareness of the project.

Engr. Eligio Cruz, the project coordinator, reported that several property owners were affected, including those whose lands were central to the project.
Sunrise Garden Corporation, an affected landowner with property in Barangay Cupang slated for development (a memorial park), executed an undertaking to build the city road at its own expense, with the cost to be later reimbursed through tax credits.
The road project became a joint venture among the Sangguniang Panlungsod, Barangays Cupang and Mayamot, and Sunrise Garden Corporation.

As the contractor began positioning construction equipment, armed guards allegedly hired by Hardrock Aggregates, Inc. blocked the access road.
On January 24, 2002, Sunrise Garden Corporation filed a complaint for damages and requested a temporary restraining order (TRO) and a writ of preliminary injunction against Hardrock Aggregates, Inc.
The trial court issued a TRO on February 15, 2002, followed by a writ of preliminary injunction on March 19, 2002, later amended on May 22, 2002, to include additional persons disrupting access—such as informal settlers and later, security personnel reportedly employed by First Alliance Real Estate Development, Inc.

Despite the TRO and amended writ, obstructive actions continued: armed guards (initially from K-9 Security Agency, later claimed to be from Forefront Security Agency) repeatedly blocked the contractor’s personnel.
A meeting was scheduled on October 8, 2002, between representatives of First Alliance Real Estate Development, Inc. and Sunrise Garden Corporation; however, the representative from First Alliance failed to appear, and subsequent verification revealed questionable business records and permits.
Sunrise Garden Corporation moved to cite the security agencies and First Alliance in contempt for noncompliance with the injunction orders.
The trial court later ordered First Alliance, which had not been a proper party to the original complaint, to comply with the amended writ because it could not demonstrate ownership or an interest in the affected property.
Responding to these issues, First Alliance and the involved security agencies filed motions and petitions for certiorari before the Court of Appeals, while Sunrise Garden Corporation and the Republic of the Philippines also filed separate petitions challenging the enforcement of the injunctions.

The lower courts and the Court of Appeals grappled with the issue of whether the injunction, originally directed against Hardrock Aggregates, could be extended by enforcement to non-parties such as First Alliance Real Estate Development, Inc. and its security personnel.
Contentions arose over whether the trial court had proper jurisdiction to require compliance from an entity that had not been impleaded in the initial complaint, thereby raising fundamental due process concerns.
Further discussions involved the applicability of Presidential Decree No. 1818 to the project, which was later rendered moot by its repeal via Republic Act No. 8975.

Whether the trial court, by issuing orders requiring First Alliance Real Estate Development, Inc. to comply with the amended writ of preliminary injunction, had proper jurisdiction over an entity that was not a party to the original complaint.
Whether enforcing the injunction against a non-party violated the constitutional requirement of due process, which mandates notice and an opportunity to be heard.

Whether the issuance and later amendment of the writ of preliminary injunction complied with Rule 58, Section 5 of the Rules of Court, which requires a hearing and prior notice before such relief is granted.
Whether the inclusion of additional persons or groups (such as security agencies and informal settlers) in the writ was procedurally and substantively correct.

Whether Presidential Decree No. 1818 (now repealed by Republic Act No. 8975) applied to the construction of the city road and impacted the legal basis for enforcing the injunction.
Whether the specific conduct and standing of First Alliance Real Estate Development, Inc.—including its failure to prove title or property interest—justified its exclusion from the injunction despite alleged interference.

Whether the voluntary appearance of First Alliance in court, when it filed pleadings challenging jurisdiction, amounted to submission to the court’s jurisdiction regarding the injunction.
Whether such special or conditional appearance could cure the jurisdictional defect for a party not originally impleaded.