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SPS. GONZALO T. DELA ROSA v. HEIRS OF JUAN VALDEZ

FACTS:

This case involves a disputed property, Lot 4, which is claimed by several parties. The defendants, spouses Cristeta dela Rosa, claim possession and ownership of the property based on a nullified Titulo de Propriedad and a Transfer Certificate of Title (TCT) in their name. However, TCT No. 451423-A was not recorded in the Registry of Deeds.

Plaintiff-intervenor North East Property Ventures, Inc. claims ownership based on a Deed of Absolute Transfer/Conveyance executed by Juan Valdez and Apolinaria Valdez, but failed to provide documents showing compliance with the terms and conditions of the transfer.

Plaintiff-intervenor spouses Juan Valdez and Apolinaria Valdez, as well as plaintiff-intervenor spouses Potenciano Malvar and Lourdes Malvar, claim ownership based on various documents including a Sales Application, Official Receipt, Order of Issuance of Patent, Sales Patent, and communication from the Land Management Bureau. They also executed a Deed of Absolute Transfer/Conveyance for part of Lot 4.

All parties sought the relief of mandatory injunction, with the prayer to be placed in possession of the disputed property. The RTC granted the joint prayer of the Valdez and Malvar spouses for the issuance of a writ of preliminary mandatory injunction, placing them in possession of Lot 4, subject to a bond.

The spouses dela Rosa filed a Motion for Reconsideration, but it was denied. They filed a Petition for Certiorari with the Court of Appeals, which dismissed the petition and upheld the RTC Orders. The spouses Dela Rosa then filed a Petition for Review before the Supreme Court, seeking a temporary restraining order (TRO) and/or writ of preliminary injunction. The Supreme Court issued a TRO enjoining the implementation of the Court of Appeals' decision and required a bond from the spouses Dela Rosa. The spouses Dela Rosa raised several errors in their petition, questioning the issuance of the preliminary mandatory injunction by the Regional Trial Court. The Court resolved to address only the issue of the preliminary injunction, emphasizing that it is a provisional remedy and not a cause of action. The grounds for the issuance of a preliminary injunction are enumerated in the Revised Rules of Court. A preliminary mandatory injunction is more carefully considered as it commands the performance of an act.

ISSUES:

  1. Whether the writ of preliminary mandatory injunction was properly issued by the RTC in favor of the spouses Valdez and spouses Malvar.

  2. Whether the Court of Appeals committed reversible error in dismissing the Petition for Certiorari filed by the spouses Dela Rosa.

  3. Whether the government still retains ownership of the land and can cancel the application even if the applicant was granted a sales patent.

  4. Whether the grant of preliminary mandatory injunction is justified in this case.

  5. Whether Sales Patent No. 38713 issued in the name of Intervenor Juan Valdez exists.

  6. Whether the defendants' claim of non-violation of Intervenor's rights is valid.

  7. Whether there is an extreme urgency or necessity for the issuance of a preliminary mandatory injunction.

  8. Whether the grant of the writ of preliminary mandatory injunction in favor of the intervenors is justified.

  9. Whether the RTC Orders amounted to a prejudgment of the case.

RULING:

  1. The RTC did not commit grave abuse of discretion in issuing the writ of preliminary mandatory injunction in favor of the spouses Valdez and spouses Malvar. The Court finds that the RTC's orders were based on substantial evidence and pertinent jurisprudence, and the issuance of the writ was justified in this clear case, free from doubt or dispute.

  2. The Court of Appeals did not commit any reversible error in dismissing the Petition for Certiorari filed by the spouses Dela Rosa.

  3. The government retains ownership of the land until the issuance of the sales patent and its subsequent registration with the Register of Deeds. The application can still be cancelled if the legal requirements have not been complied with. The issuance of the sales patent and its registration divests the government of title to the land.

  4. The grant of preliminary mandatory injunction is justified in this case because the right to possession during the pendency of the main case is clear, there is willful and unlawful invasion of the plaintiffs' rights, and the effect of the injunction is to re-establish and maintain a pre-existing and continuing relationship between the parties that was arbitrarily interrupted by the defendant.

  5. Sales Patent No. 38713 issued in the name of Intervenor Juan Valdez exists, as evidenced by official records and documents on record.

  6. The defendants' claim of non-violation of Intervenor's rights is false, as the existence of Sales Patent No. 38713 has been proven.

  7. There is an extreme urgency and necessity for the issuance of a preliminary mandatory injunction due to the defendants' intrusion into the subject land and their indiscriminate disposition of the property, causing grave and irreparable damages to the Intervenors.

  8. The grant of the writ of preliminary mandatory injunction in favor of the intervenors is justified. There are exceptional circumstances and ample justifications for the grant, such as the issuance of a sales patent to Juan Valdez, making him the equitable owner of the subject property, and the acknowledgment of the transfer of the property to the spouses Malvar. In contrast, the title of the spouses Dela Rosa to the property is nebulous, traced back to a title that was already declared null and void.

  9. The RTC Orders did not amount to a prejudgment of the case. They only settled the question of possession of the subject property while the main case is still being heard. The findings of fact and opinion in the RTC Orders are merely interlocutory in nature. The RTC is not precluded from proceeding with the main case to determine the rightful owner and possessor of the property.

PRINCIPLES:

  • A preliminary injunction is a provisional remedy, adjunct to the main case and subject to the latter's outcome. It is not a cause of action in itself.

  • A preliminary mandatory injunction is justified only in a clear case, free from doubt or dispute. When the complainant's right is doubtful or disputed, the issuance of a writ of preliminary mandatory injunction is improper.

  • The grant or denial of a writ of preliminary injunction in a pending case rests on the sound discretion of the court taking cognizance of the case. Grave abuse of discretion in the issuance of writs of preliminary injunction implies a capricious and whimsical exercise of judgment that is equivalent to lack of jurisdiction.

  • The government retains ownership of the land until the issuance of the sales patent and its subsequent registration with the Register of Deeds.

  • The issuance of the sales patent and its registration divests the government of title to the land.

  • The grant of preliminary mandatory injunction is justified in cases where the right to possession is clear, there is willful and unlawful invasion of rights, and the injunction serves to re-establish a pre-existing relationship.

  • Ownership of land can be a basis for the issuance of a preliminary mandatory injunction.

  • Official records and documents on record serve as evidence of the existence of a sales patent.

  • The assessment and evaluation of evidence in the issuance of a writ of preliminary injunction involves findings of facts normally left to the trial court for its conclusive determination. Conclusions and findings of fact of the trial court are entitled to great weight and should not be disturbed on appeal, unless strong and cogent reasons dictate otherwise. Levi Strauss (Phils.) Inc. v. Vogue Traders Clothing Company.

  • A writ of preliminary injunction is based on initial and incomplete evidence, with the sole object of preserving the status quo until the merits of the case can be heard. Such a writ is interlocutory in nature and would become a prejudgment of the case only if it grants the main prayer in the complaint or responsive pleading, leaving nothing else for the trial court to try except incidental matters.