Case Summary (G.R. No. 9717)
Applicable Law
The decision is governed by the 1987 Philippine Constitution and relevant provisions from the Rules of Court, specifically regarding the issuance of preliminary injunctions.
Summary of the Case
This case concerns a parcel of land previously owned by respondent Christopher San Agustin, which was sold to spouses Enrique and Angelina Camacho. The sale price was P2.5 million, with a down payment of P100,000, and an agreement that the remainder would be paid after spouses Camacho secured a loan using the property as collateral. After the spouses defaulted on their loan from FGRDC, a dacion en pago was executed, transferring ownership of the property to FGRDC, which led to respondent's subsequent legal filings.
Order of the Trial Court
The RTC initially denied respondent's application for a preliminary injunction to prevent petitioner from evicting him, arguing that respondent had already sold the property to the Camachos and thus lacked a claim to its possession. This ruling was reinforced when the RTC denied the motion for reconsideration, maintaining that the essential cause of action remained the collection of the unpaid balance from the Camachos.
Court of Appeals Ruling
The Court of Appeals reversed the RTC's decision, asserting that FGRDC should not possess the property due to its awareness of the original agreement between respondent and the Camachos. This Court emphasized that a defect in the title should have prompted caution on FGRDC's part, allowing it to grant the requested injunction instead.
Issues Raised
The petitioner raised two primary issues:
- Whether the factual findings of the Court of Appeals were unsupported by evidence or misapprehended.
- Whether petitioner was a purchaser in good faith, thereby entitled to the possession of the property.
Principal Issue: Possession Pendente Lite
The central legal question was whether respondent was entitled to possess the property while his main complaint against the Camachos and FGRDC was pending. The Court underscored the necessity of preserving the status quo, which in this case pertained to the respondent's continuous possession of his family home. It held that to dispossess the respondent pending resolution would be unjust.
Prima Facie Right to Possess
Respondent's claim for rescission of the sale and annulment of the dacion en pago indicated a strong prima facie right to possession based on his longstanding ownership and possession of the property, along with substantial irregularities in the proceedings against him. The Court found that evidence of the respondent's original ownership and the various complications of the transactions involving the Camachos support his right to remain in possession.
Grave Injustice in a Transfer of Possession
The Court highlighted that allowing the petitioner to take immediate possession would cause grave injustice to the respondent, who had lived in the property since 1967. Displacing him would significantly alter the status quo to his detriment, particularly as the circumstances
...continue readingCase Syllabus (G.R. No. 9717)
Statement of the Case
- The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the April 28, 2000 Decision of the Court of Appeals (CA) in CA-GR SP No. 49083 and the August 10, 2000 CA Resolution denying reconsideration.
- The dispositive portion of the CA Decision set aside the trial court's orders and granted an injunction preventing First Global Realty Development Corporation (FGRDC) from taking possession of the subject property until the resolution of the civil case pending before the trial court.
Facts of the Case
- The subject property is a parcel of land located at No. 3491 Honda St., Bo. Pinagkaisahan, Makati City, previously covered by TCT No. 180235 issued in the name of respondent's mother, Lilian Sales-San Agustin.
- Respondent Christopher San Agustin, along with his family, has been in possession of the property since 1967.
- The controversy began when the property was sold to spouses Enrique and Angelina Camacho in 1994 for P2.5 million, with a partial payment of P100,000.
- Spouses Camacho secured a loan from FGRDC using the property as collateral but defaulted on their payments, prompting FGRDC to file for foreclosure.
- A dacion en pago was executed by spouses Camacho in favor of FGRDC, leading to the issuance of TCT No. 209050 in FGRDC&