Ramos v. Court of Appeals
REITERATIONFacts
The Antecedents: Respondents Rufino, Rufina, Ligaya, Francisco, Erlinda Clemente, Ofelia Quinto, and Medolina Quinto were co-owners of a fishpond. They executed a contract of lease over the fishpond in favor of petitioner Hugo Ramos, Mamerto Borlongan, and Honesto Bernal for ten years, later extended by three years. Subsequently, the Quintos executed a KASUNDUAN NG SANLAAN NA MAYROONG PAGBIBILE (Real Estate Mortgage With Sale) over their 7/14 share in favor of petitioner. Later, Medolina alone conveyed her 1/4 participation to petitioner. Procedural History: Petitioner alleged that Lourdes Bernal, niece of Honesto Bernal, illegally took possession of the fishpond. Petitioner filed Civil Case No. 7201-M to recover possession. The trial court issued a writ of preliminary injunction against Lourdes Bernal. Bernal elevated this to the Court of Appeals, which set aside the writ. Upon remand, the lower court issued orders restoring Bernal to possession. The Petition: Petitioner invoked the KASUNDUANs to defeat Bernal's claim, arguing they were supervening causes that rendered restoration inequitable. The Supreme Court reviewed the Court of Appeals' decision sustaining the trial court's orders.
Issue(s)
Whether the trial court's orders restoring Lourdes Bernal to possession, after the dissolution of the writ of preliminary injunction by the Court of Appeals, were proper. Whether the KASUNDUANs executed by the Quintos in favor of the petitioner could be used to justify the outright dispossession of Lourdes Bernal pending trial.
Ruling
The petition is DISMISSED. The case is REMANDED to the Regional Trial Court of Bulacan, Branch 18 (Civil Case No. 7201-M), for further proceedings.
Ratio Decidendi
On the propriety of restoring Lourdes Bernal to possession: The restoration of Lourdes Bernal to possession was a direct consequence of the dissolution of the writ of preliminary injunction by the Court of Appeals. The Supreme Court reiterated the well-settled principle that injunction does not lie to take property away from one party and give it to another; its general function is to preserve the status quo ante. The exceptions provided in the Rules of Court for preliminary mandatory injunctions in forcible entry and ejectment cases were noted as not applicable to the present case, which is an accion publiciana within the jurisdiction of the Regional Trial Court. Therefore, restoring Bernal to possession was merely to maintain the status quo prior to the injunction, not a final determination of her right to the property. On the effect of the KASUNDUANs: The Supreme Court held that the KASUNDUANs, even if they vested ownership in the petitioner, were matters of evidence to be presented and proven at trial. They could not, by themselves, justify the outright dispossession of Lourdes Bernal, especially since Bernal disputed the nature of these agreements, claiming they were merely mortgages pending foreclosure. The Court emphasized the distinction between the right of possession (jus possesionis) and ownership. The petitioner must demonstrate Bernal's claim was without basis, and he could not rely solely on the bare provisions of the KASUNDUANs to oust her. Furthermore, even if the KASUNDUANs were valid, they only conveyed ownership of the Quintos' shares (half of the fishpond), not the entire property, thus precluding a claim to all of it.
Main Doctrine
A writ of preliminary injunction generally serves to preserve the status quo ante and does not lie to take property away from one party and give it to another, except in specific instances like forcible entry or ejectment cases under the Rules of Court. The validity of alleged conveyance instruments must be determined in a trial on the merits, and cannot be used to summarily dispossess a party claiming possession under an independent right.