FACTS:

Petitioner Maximo Savellano Jr. filed a complaint against private respondents Nena de Guzman, Ben de Guzman, Cecilio Cruz, and John Doe for the "Recovery of Possession of Real Property with Prayer for the Issuance of a Temporary Restraining Order and Writs of Preliminary Prohibitory and Mandatory Injunction." Petitioner claimed to be the registered owner of three parcels of land in San Mateo, Rizal, which were allegedly occupied by the de Guzmans, Cruz, and others without his knowledge and consent.

Private respondents denied the allegations, stating that they had been in peaceful possession of the property since 1976. They presented real property tax declarations and tax receipts to support their claim. They also argued that the certificates of title provided by petitioner did not cover the premises they occupied.

To resolve this issue, the trial court ordered a survey of the property. The survey report indicated that there were three houses within petitioner's claim, one portion of the property was encroached by a concrete fence, and some corners were not monumented.

Both parties presented evidence regarding the issuance of writs of preliminary prohibitory and mandatory injunction. Petitioner moved for the waiver of private respondents' right to present documentary evidence, which the court granted. The trial court eventually issued an order stating that petitioner had established his right to the writs of preliminary injunction based on the Santos v. Court of Appeals ruling.

Private respondents sought reconsideration and raised objections to the accuracy and correctness of the survey report. They argued that the report violated certain provisions and was not approved by the Executive Director of the DENR for Region IV.

Petitioner filed a motion for enforcement of the writ of injunction, which was granted. Private respondents filed an omnibus motion seeking the resolution of their motion for reconsideration. The trial court denied their motion.

On appeal, the Court of Appeals nullified the trial court's order, finding that it was patently erroneous to grant a resolution to vacate in the writ of preliminary injunction.

ISSUES:

1. Whether private respondents should be required to vacate the three parcels of land in question.

2. Whether the trial court correctly relied on Santos v. Court of Appeals in granting the writ of preliminary prohibitory and mandatory injunction.

RULING:

1. The Court of Appeals nullified the Order of the trial court, ruling that the resolution to vacate granted in the writ of preliminary injunction was patently erroneous since it preempted the decision on the main case.

2. The Court of Appeals did not directly address the issue on whether the trial court correctly relied on Santos v. Court of Appeals in granting the writ of preliminary injunction.

PRINCIPLES:

• The general rule prohibiting the use of injunction to transfer possession or control of property from one party to the other does not apply when (a) the applicant has clearly established his rights over the disputed property, and (b) the defendant is merely an intruder; or (c) where the action seeks to prevent a purchaser at an auction sale from molesting the rights of a debtor's co-owner whose rights have not been affected by the sale (as established in Santos v. Court of Appeals).