Case Summary (G.R. No. 140228)
Petitioners
Petitioners are heirs and descendants of Pedro Medina by his two marriages and include, among others, Francisco, Maria, Raymundo, Enrique, Edgardo and many other Medinas; they assert they are co-owners of two parcels sold in the 1960s to respondent and that the deeds of sale and signatures are simulated or fictitious.
Respondent
Respondent is Greenfield Development Corporation, which acquired the properties through a series of notarized instruments (a Contract to Sell dated June 5, 1962; a Deed of Sale dated June 27, 1962; and a Deed of Absolute Sale with Mortgage dated September 4, 1964) and subsequently registered Torrens titles in its name.
Key Dates and Documents
- June 5, 1962: Notarized Contract to Sell executed by Pedro Medina, Alberto Medina and Nazaria Cruz (Lot 90‑A).
- June 27, 1962: Notarized Deed of Sale (Lot 90‑A) signed by several Medinas and Nazaria Cruz.
- September 4, 1964: Notarized Deed of Absolute Sale with Mortgage (Lot 90‑B) executed by several Medinas and Nazaria Cruz.
- Titles: Respondent registered titles as TCT Nos. 100578 and 133444; consolidation and later registration under TCT Nos. 202295–202297 on July 19, 1995.
- November 6, 1998: Petitioners filed Civil Case No. 98‑233 (annulment of titles and deeds, reconveyance, damages, with preliminary injunction).
- January 18, 1999: RTC issued a resolution granting petitioners’ request for injunctive relief (subject to bond).
- July 16, 1999: Court of Appeals (CA) nullified the RTC’s injunction.
- November 19, 2004: Supreme Court rendered the decision under review.
Procedural History
Petitioners filed Civil Case No. 98‑233 seeking annulment of deeds and titles and obtained a preliminary injunction from the RTC enjoining respondent and its agents from preventing petitioners and their caretaker from entering and exercising rights on the parcels. Respondent sought relief from the CA via special civil action, which nullified the RTC injunction. Petitioners sought review before the Supreme Court, challenging the CA’s nullification and several underlying findings.
Central Issue Presented
Whether the RTC committed grave abuse of discretion in issuing the writ of preliminary injunction in Civil Case No. 98‑233, and whether the CA erred in nullifying that writ.
Trial Court’s Reasoning for Injunction
The RTC issued the injunction because it found suspect the acquisition by respondent: the Contract to Sell for Lot 90‑A was not signed by all registered owners; no subsequent valid deed of sale supported issuance of title; the Deed of Absolute Sale with Mortgage for Lot 90‑B raised doubts because its “absoluteness” was contradicted by a mortgage; several registered owners denied executing the documents. The RTC concluded that until the merits were resolved at trial, respondent’s asserted ownership, if allowed, would cause irreparable injury to petitioners.
Court of Appeals’ Reasoning
The CA found that the RTC had relied largely on petitioners’ pleadings without substantial evidence and improperly disregarded the presumption of regularity accorded to notarized public instruments and the conclusive nature of Torrens titles. The CA held respondent was in constructive possession as registered owner and concluded petitioners’ action to impugn the titles was barred by prescription. Accordingly, the CA nullified the RTC’s injunction.
Legal Standard for Preliminary Injunction
The Court applied Section 3, Rule 58 of the Rules of Court. A preliminary injunction may issue when: (a) the applicant is entitled to the relief demanded which consists, in whole or in part, of restraining acts complained of; (b) continuing the acts complained of would probably work injustice to the applicant; or (c) some act is being done or threatened that would probably violate the applicant’s rights and render judgment ineffectual. The requisites are summarized as: (1) a right in esse or a clear and unmistakable right to be protected; (2) a violation of that right; and (3) urgency/necessity to prevent serious damage.
Burden of Proof at the Injunction Stage
The Supreme Court emphasized that the propriety of a preliminary injunction is determined from the pleadings and documents attached thereto; petitioners bore the burden of establishing a prima facie clear and unmistakable right. Where the complainant’s title is doubtful or disputed, injunctive relief is improper. The Court noted that mere possibility of irreparable damage without proof of an actual existing right is insufficient.
Presumption of Regularity for Notarized Instruments
Notarized and acknowledged public instruments enjoy a presumption of regularity and are prima facie evidence of the facts stated therein. To overcome that presumption, clear and convincing evidence of spoliation or forgery must be presented. In this case, respondent’s notarized conveyances weighed heavily against petitioners’ bare allegations.
Torrens Titles and Presumption of Validity
Torrens registration provides strong presumptions that titles are regularly issued and valid. The Court indicated that titles registered under the Torrens system constitute generally conclusive evidence of ownership for purposes of interim relief, absent clear and convincing evidence to the contrary.
Possession versus Ownership
The Court reiterated the legal distinction between possession and ownership: possession, even if actual, is not conclusive proof of ownership; nor is non‑possession inconsistent with ownership. The execution of a public deed of conveyance is equivalent to delivery under Article 1498 of the Civil Code; thus, ownership and possession may be regarded as transferred by the notarized conveyances absent evidence to the contrary. Re
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Procedural Posture
- Petition for review on certiorari to the Supreme Court assails the Court of Appeals decision that nullified the writ of preliminary injunction issued by the Regional Trial Court (RTC) of Muntinlupa City, Branch 276, in Civil Case No. 98-233.
- The RTC issued a resolution on January 18, 1999 granting petitioners' prayer for injunctive relief; the dispositive portion enjoined respondent Greenfield Development Corporation, its security guards, agents and representatives from preventing petitioners and their caretaker Santos Arevalo from entering and exiting the subject premises and from preventing them from exercising their property rights, conditioned on a bond of P100,000.00.
- Respondent filed a special civil action (certiorari and prohibition) in the Court of Appeals (CA-G.R. SP No. 52015), which on July 16, 1999 rendered a decision nullifying the RTC resolution.
- Petitioners elevated the matter to the Supreme Court, raising multiple assignments of error focused on the CA’s reliance on respondent’s pleadings, the validity of the deeds and Torrens titles, possession issues, and prescription.
Parties and Standing / Identity of Petitioners
- Petitioners are the grandchildren of Pedro Medina from two marriages and include numerous named descendants and relatives; the complaint also includes the heirs of Nazaria Cruz as unwilling co-plaintiffs.
- Petitioners allege co-ownership of the two parcels of land now recorded in respondent’s name and assert that the deeds of sale were simulated and signatures were forged; they also allege continued physical possession through a caretaker (Santos Arevalo) and some family residencies on a portion of the property.
- Respondent is Greenfield Development Corporation, which holds Torrens titles to the parcels and denies petitioners’ claims; respondent counterclaims that Santos Arevalo was its employee/caretaker.
Factual Background — Documents, Dates, and Titles
- June 5, 1962: Pedro Medina, Alberto Medina, and Nazaria Cruz executed a notarized Contract to Sell in favor of Greenfield Development Corporation over a parcel then covered by TCT No. 100177 (Lot 90-A), measuring 17,121 sq. m.
- June 27, 1962: A notarized Deed of Sale was executed in favor of respondent and signed by Pedro, Cornelio, Brigida, Balbino, Gregoria, Crisanta, Rosila, Alberto (all surnamed Medina), and Nazaria Cruz as vendors (annexed in the record).
- September 4, 1964: A notarized Deed of Absolute Sale with Mortgage was executed in favor of respondent over Lot 90-B (then covered by TCT No. 100178), measuring 16,291 sq. m., signed by the same group of vendors and Nazaria Cruz (annexed).
- By virtue of these transactions, respondent registered the two parcels: TCT No. 100578 (Lot 90-A) and TCT No. 133444 (Lot 90-B), and subsequently consolidated and registered the properties under TCT Nos. 202295, 202296 and 202297 on July 19, 1995.
- July 13, 1998: Petitioners had an adverse claim annotated on the titles; after the annotation, respondent is said to have fenced the property and posted security personnel, allegedly obstructing petitioners’ ingress and egress.
Cause of Action, Reliefs Sought, and Interim Relief
- Petitioners instituted Civil Case No. 98-233 on November 6, 1998, for annulment of titles and deeds, reconveyance, damages, with a prayer for preliminary injunction and restraining order against respondent and the Register of Deeds of Makati.
- The complaint alleges simulation and forgery in the deeds of sale and asserts continued possession by petitioners or their caretaker.
- Petitioners sought a temporary restraining order and a writ of preliminary injunction to prevent respondent and its agents from preventing petitioners from exercising rights over the properties.
Trial Court (RTC) Ruling — Grounds for Granting Injunction
- The RTC granted the injunctive relief, expressing suspicion about the acquisition by respondent:
- It found irregularities in the Contract to Sell (Lot 90-A), notably that not all registered owners signed and that no subsequent deed of sale followed the Contract to Sell.
- It questioned the validity of the instrument denominated “Deed of Absolute Sale with Mortgage” for Lot 90-B, noting an apparent contradiction between absoluteness of sale and the mortgage provision, and that registered owners denied executing the deed.
- The RTC held that, until trial on the merits determines whether the properties were actually sold to respondent, irreparable injury would visit the landowners if respondent’s claim to ownership were allowed to stand without injunction.
- The injunctive order included a condition that petitioners post a bond of P100,000.00.
Court of Appeals (CA) Ruling — Grounds for Nullification of Injunction
- The CA annulled the RTC’s resolution, reasoning as follows:
- The RTC relied mainly on petitioners’ allegations in the complaint without substantial evidence.
- The CA emphasized the presumption of validity attached to duly notarized deed