Case Summary (G.R. No. 208343)
Petitioner’s Allegations and Prayer for Relief
On October 3, 2005, petitioners charged respondent and its agents with obstructing their entry into their titled properties on three occasions in August 2005. They sought:
- Moral, exemplary, and liquidated damages;
- A Temporary Restraining Order (TRO) and Writ of Preliminary Injunction (WPI) to bar any interference with their ownership and possession;
- Permanent injunction after trial.
Respondent’s Defenses
Respondent and Marivalles contended that petitioners lacked title and possession. They asserted:
- The true owners are third parties who contracted Optimum to secure the land;
- Petitioners’ deeds of sale were forged;
- Pending cancellation proceedings challenged petitioners’ titles;
- They acted in good faith under a valid security service contract;
- No wrongful act occurred, warranting dismissal and costs in their favor.
TIPCO denied involvement, denying it employed guards or claimed interest in the properties.
Regional Trial Court Ruling
On October 6, 2010, the RTC granted the WPI, finding petitioners’ registered titles sufficient to establish their right to possess. It enjoined respondent and co-defendants from interference. A motion for reconsideration was denied on August 31, 2011.
Court of Appeals Ruling
In a decision dated March 25, 2013, the CA:
- Lifted the WPI and reversed the RTC, holding that petitioners’ title and possession were disputed and their right not clearly established;
- Noted that issuance of a WPI must preserve the last peaceful status quo and not effect a transfer of possession;
- Found respondent not a real party in interest as its security contract had lapsed;
- Declared that the alleged true owners were indispensable parties.
A July 22, 2013 CA resolution denied petitioners’ motion for reconsideration.
Issue
Whether the CA erred in lifting the WPI issued by the RTC and in dismissing petitioners’ complaint.
Applicable Law
1987 Philippine Constitution; Rules of Court governing injunctive relief; established jurisprudence on real and indispensable parties.
Supreme Court Ruling and Ratio
The petition was partly meritorious:
Injunctive Relief Parameters
- A WPI requires a clear, existing right and a threat of violation.
- It is preservative, maintaining the last peaceable status quo, not effecting dispossession.
- Petitioners, though registered owners, failed to prove prior actual possession at the time of the incidents.
- Respondent vacated the premises upon contract expiration, rendering the WPI moot.
- RTC issuance constituted grave abuse of discretion.
=> CA correctly lifted the WPI.
Parties and Dismissal
- The CA mischaracterized the alleged true owners as indispensable parties.
- Distinction: a real party in interest benefits or is injured by a judgment; an indispensable party is one without whom no final determination can be made.
- Non-joinder of an indispensable party is not ground f
Case Syllabus (G.R. No. 208343)
Facts
- On October 3, 2005, petitioners filed Civil Case No. 12307 for “Damages with Application for a Temporary Restraining Order and Writ of Preliminary Injunction,” claiming respondent and its security guards barred them from entering eight titled parcels in Mabalacat, Pampanga.
- The subject lands were covered by TCT Nos. 576602-R, 578037-R, 578038-R, 578039-R, 575138-R, 575112-R, 576601-R, and 576603-R, registered in petitioners’ names.
- Petitioners prayed for moral, exemplary, and liquidated damages; issuance of TRO and WPI; and eventual permanent injunction.
- Respondent and guard Ronnie Marivalles opposed, asserting petitioners were not the true owners, that Margarita dela Rosa et al. held title and authorized Ranilo Arceo by Special Power of Attorney to contract security services, and that petitioners’ deeds bore forged signatures. A pending cancellation case against petitioners’ titles by an original patent holder was also cited.
- TIPCO Estate Corporation disclaimed involvement, denying it hired guards or claimed ownership.
Trial Court Ruling
- RTC Angeles City, Branch 62 (Order of October 6, 2010) granted the WPI, finding petitioners as registered owners with a clear right to possession; enjoined respondent and co-defendants from interference.
- Motions for reconsideration by respondent and TIPCO were denied (Order of August 31, 2011).
Court of Appeals Ruling
- CA (Decision of March 25, 2013)