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P/SUPT. FELIXBERTO CASTILLO v. DR. AMANDA T. CRUZ

FACTS:

The petitioners in this case are employees and members of the local police force of the City Government of Malolos. On the other hand, the respondents are Amanda Cruz and her co-respondents. Amanda and her husband had leased a parcel of land from the Provincial Government of Bulacan but they refused to vacate despite demands from the lessor. As a result, the lessor filed a complaint for unlawful detainer against them, and a judgment was rendered against them by the Municipal Trial Court (MTC) of Bulacan. This judgment was later affirmed by the Regional Trial Court (RTC) and became final and executory.

Even though the judgment was final, the spouses still refused to leave the property. They filed various cases, including an injunction before Branch 10 of the RTC. In this particular case, a permanent writ of injunction was issued to prevent the execution of the final judgment. Subsequently, after the boundaries of the property were determined by a Geodetic Engineer's Report submitted to the MTC, a second writ of demolition was issued.

However, the spouses filed a motion for a temporary restraining order (TRO) at the RTC, which was granted. Nevertheless, the demolition had already been implemented and the petitioners, who were deployed to protect the property, entered the premises. Consequently, the respondents resisted, leading to their arrest.

In response to their arrest, the respondents filed a petition for writs of amparo and habeas data. Their petition was granted by the RTC. This decision is now being questioned by the petitioners in this petition for review on certiorari.

ISSUES:

  1. Whether the RTC erred in issuing writs of amparo and habeas data based on the allegations of the petition.

RULING:

  1. The Supreme Court ruled that the RTC erred in granting the issuance of writs of amparo and habeas data. The Court held that the allegations in the petition were insufficient in substance as they primarily involved property rights and did not meet the threshold requirement that respondents' rights to life, liberty, and security were violated or threatened by unlawful acts or omissions. The Court highlighted that the writs of amparo and habeas data are intended to address extraordinary cases of extrajudicial killings and enforced disappearances, which were not demonstrated in this case.

PRINCIPLES:

  1. Writ of Amparo: The writ of amparo is a remedy available to any person whose right to life, liberty, and security is violated or threatened with violation by an unlawful act or omission of a public official or employee, or of a private individual or entity. It specifically covers extrajudicial killings and enforced disappearances or threats thereof.

  2. Writ of Habeas Data: The writ of habeas data is a remedy available to any person whose right to privacy in life, liberty, or security is violated or threatened by an unlawful act or omission of a public official or employee or of a private individual or entity engaged in the gathering, collecting, or storing of data or information regarding the person, family, home, and correspondence of the aggrieved party.

  3. Property Disputes and the Writs: The writs of amparo and habeas data do not cover property disputes unless there is a demonstrable violation or threat to the rights to life, liberty, and security. The extraordinary character of these writs demands that petitions must show a clear and present danger to these rights rather than merely raising property or commercial issues.

  4. Sufficiency of Allegations: Petitions for the issuance of writs of amparo and habeas data must be supported by justifying allegations of fact detailing the circumstances of how and to what extent a threat to or violation of the rights to life, liberty, and security is committed or imminent.

  5. Imminent or Continuing Threat: The existence of an imminent or continuing threat to the rights to life, liberty, and security must be compellingly shown in supporting affidavits for the writs to be issued.

  6. Misuse of Extraordinary Remedies: Petitions for writs of amparo and habeas data cannot be used as tools to delay or stall the execution of final and executory decisions, particularly in property disputes.