SPS. CEFERINO C. LAUS v. OPTIMUM SECURITY SERVICES

FACTS:

Petitioners filed a complaint for damages against respondent and other defendants, alleging that they were prevented by armed security guards from entering their parcels of land. They sought damages, a temporary restraining order (TRO) and writ of preliminary injunction (WPI), and a permanent injunction. Respondent and other defendants argued that petitioners were not the owners of the subject properties and that they acted in good faith. TIPCO denied preventing petitioners from entering the properties. The RTC granted the WPI, finding that petitioners presented sufficient evidence of ownership. Respondent and TIPCO's motion for reconsideration was denied. The CA reversed the RTC ruling, lifted the WPI, and dismissed the complaint. The CA held that petitioners' ownership was under contest and failed to establish prior possession. The CA also found that respondent was not a real party in interest. Petitioners' motion for reconsideration was denied, prompting them to file a petition for review before the Court.

ISSUES:

  1. Whether or not the Court of Appeals erred in lifting the WPI issued by the RTC.

  2. Whether or not the Court of Appeals erred in dismissing petitioners' complaint.

RULING:

  1. The Court of Appeals did not err in lifting the WPI issued by the RTC and in dismissing petitioners' complaint.

PRINCIPLES:

  • A writ of preliminary injunction is intended to preserve the status quo ante or the last actual, peaceful, and uncontested status prior to the controversy.

  • A claimant's title must be clearly established by law before a writ of preliminary injunction can be issued.

  • A real party in interest refers to one who would be benefited or injured by the judgment, or one who is entitled to the avails of the suit.

  • The alleged real owners of the subject properties are the real parties in interest in a case involving the determination of ownership.