FACTS:

The respondents claim to be the absolute owners of a piece of land in Parañaque City, originally owned by their great grandfather, Jose Vitalez. The land was transferred from Jose to his son, Pedro, in 1930. Pedro occupied and possessed the land, obtaining a tax declaration in his name in 1966. He later transferred his rights to respondent Mario Ebio in 1987, who obtained new tax declarations in his name.

In 1999, a resolution from the Sangguniang Barangay sought assistance from the city government for the construction of an access road through the respondents' land. The respondents opposed the project and registered their ownership claim. In 2003, coconut trees on the land were cut by officials from the barangay and city planning office, prompting the respondents to file complaints. Meetings with government officials were held, but no agreement was reached. The City Administrator eventually ordered the respondents to vacate the land in 2005, leading them to file a petition for a writ of preliminary injunction.

The Regional Trial Court denied the petition, stating that the respondents failed to prove their right to the property and did not include the Republic of the Philippines as an indispensable party. The respondents' motion for reconsideration was also denied. They then appealed the case to the Court of Appeals, which ruled in their favor. The Court of Appeals concluded that the respondents and their predecessors-in-interest have been in exclusive possession of the land since 1930 and have made improvements on it. They held that the respondents acquired ownership through acquisitive prescription, and the registration of the neighboring property in the name of Guaranteed Homes does not affect their claim.

ISSUES:

1. Whether the State is an indispensable party to respondents' action for a prohibitory injunction.

2. Whether the character of respondents' possession and occupation of the subject property entitles them to avail of the relief of a prohibitory injunction.

RULING:

1. The State is not an indispensable party to the action for prohibitory injunction. The State is neither a necessary nor an indispensable party to an action where no positive act shall be required from it or where no obligation shall be imposed upon it. Moreover, the action seeks to enjoin the local government of Parañaque; thus, the inclusion of the State is unnecessary.

2. The character of respondents' possession and occupation of the subject property entitles them to avail of the relief of a prohibitory injunction. The respondents have proven that they have title by acquisitive prescription due to their exclusive possession and payment of real property taxes for decades. The possession dates back to 1930, and neither Guaranteed Homes, Inc. nor the local government of Parañaque sought to register the accreted portion. Consequently, respondents have acquired ownership through prescription.

PRINCIPLES:

• Acquisitive Prescription: Ownership of the property may be acquired through long-term possession, as seen in the respondents' longstanding occupation of the land.

• Article 457 of the Civil Code: Owners of lands adjoining banks of rivers own the accretion that gradually receives from the effects of the current of the waters.

• Article 84 of the Spanish Law of Waters of 1866: Accretions deposited gradually upon lands contiguous to creeks, streams, rivers, and lakes, by accessions or sediments from the waters thereof, belong to the owners of such lands.

• Indispensable Parties: Those whose interest is such that a final decree would necessarily affect their right and without whom the court cannot proceed.

• Prohibitory Injunction: Requires proof of a clear and unmistakable right in esse to obtain an injunctive relief.

• Principle of Nemo dat quod non habet: No one can give what they do not have, applicable even against the State.