First Global Realty And Development Corporation v. Christopher San Agustin
REITERATIONFacts
The Antecedents: Respondent Christopher San Agustin and his family had been in possession of a parcel of land and the house thereon since 1967. The property was initially registered under the name of respondent's mother. In 1994, the property was sold to spouses Enrique and Angelina Camacho for ₱2.5 million. The spouses paid ₱100,000, with the balance of ₱2.4 million to be paid upon transfer of the title to their name. The title was transferred to the spouses Camacho on May 26, 1994. The spouses Camacho obtained a loan of ₱1.190 million from petitioner First Global Realty and Development Corporation (FGRDC), using the subject property as collateral. The spouses Camacho failed to pay the balance of the purchase price to respondent and also defaulted on their loan with FGRDC. FGRDC initiated foreclosure proceedings, which led to a decision ordering the foreclosure. However, the spouses Camacho executed a dacion en pago in favor of FGRDC, which was registered on April 29, 1997, leading to the issuance of a new title in FGRDC's name. On September 8, 1997, FGRDC demanded rentals from respondent, and upon non-compliance, filed a motion for a writ of possession. Procedural History: Respondent filed a motion for intervention before the Regional Trial Court (RTC) handling the foreclosure case, seeking rescission of the deed of sale, annulment of the dacion en pago, and cancellation of FGRDC's title. Finding intervention futile, respondent filed a separate complaint for rescission of the deed of sale, annulment of the dacion en pago, and cancellation of title, with a prayer for a temporary restraining order and/or writ of injunction. The RTC denied respondent's prayer for a preliminary injunction. The Court of Appeals (CA) reversed the RTC, setting aside the RTC's orders and enjoining FGRDC from taking possession of the property until the main case was resolved. The Petition: FGRDC filed a Petition for Review on Certiorari before the Supreme Court, challenging the CA's decision and resolution, raising issues of factual findings and whether FGRDC was a purchaser in good faith and for value entitled to possession.
Issue(s)
Whether the factual findings of the Court of Appeals are devoid of support by the evidence or based on a misapprehension of facts. Whether petitioner is a purchaser in good faith and for value, and thus entitled to the possession of the litigated property. Whether respondent is entitled to the possession of the property pendente lite.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that respondent was entitled to the possession of the property pendente lite.
Ratio Decidendi
On the factual findings of the Court of Appeals: The provided text does not contain any ratio decidendi related to whether the factual findings of the Court of Appeals are devoid of support by the evidence or based on a misapprehension of facts. Therefore, no ratio can be provided for this issue based on the given text. On whether petitioner is a purchaser in good faith and for value: The provided text does not contain any ratio decidendi related to whether the petitioner is a purchaser in good faith and for value. Therefore, no ratio can be provided for this issue based on the given text. On the entitlement to possession pendente lite: The Court affirmed the CA's grant of a preliminary injunction, holding that respondent had sufficiently demonstrated a prima facie right to the relief demanded and that grave and irreparable injury would befall him and his family if the injunctive relief were denied. The purpose of a preliminary injunction is to preserve the status quo ante, which in this case is the possession of the property by respondent and his family. The Court reiterated that an injunction is issued to prevent threatened or continuous irremediable injury before claims can be adjudicated, and its sole aim is to preserve the status quo until the merits of the case can be heard fully. Therefore, it will be issued only upon a showing of a clear and unmistakable right that is violated and an urgent and permanent necessity for its issuance. The Court found that respondent had shown a prima facie right to the relief demanded in his complaint, which sought rescission of the deed of sale, annulment of the dacion en pago, and cancellation of FGRDC's title. The Court noted the agreement between respondent and the Camacho spouses for the sale of the property for ₱2.5 million, with an initial payment of ₱100,000 and the balance to be paid upon securing a loan using the property as collateral. The Court highlighted the irregularities surrounding the dacion en pago, including its registration in 1997 despite being executed in 1994, and the discrepancy between the purchase price and the amount of the dacion en pago. These irregularities were deemed serious enough to allow respondent to possess the property pendente lite. The Court agreed with the CA that allowing petitioner to take immediate possession would result in grave injustice. The ownership of the property, the validity of the sale between respondent and the Camachos, and the legitimacy of the dacion en pago were still subject to determination. The Court emphasized that respondent and his family had been in possession of the property as their family home since 1967, and dispossessing them would alter the status quo to their detriment. The Court also noted that respondent, who sold his family home for ₱2.5 million, would be left homeless with only ₱100,000 if dispossessed, which equity and justice dictated should be prevented.
Main Doctrine
A writ of preliminary injunction may be granted to preserve the status quo pending litigation, provided the applicant demonstrates a prima facie right to the relief demanded and that grave and irreparable injury would result from its denial. The applicant must show that the commission, continuance, or non-performance of the act complained of during the litigation would probably work injustice.