Republic v. Navy Officers’ Village Homeowners’ Association, Inc.
REITERATIONFacts
The Antecedents: Officers of the Philippine Navy were permitted to lease and occupy housing units at the Navy Village in Fort Bonifacio. Respondents Commodore Eduardo T. Domingo and Commodore Rodolfo Simon occupied such units. These officers, both active and retired, formed the respondent Navy Officers’ Village Homeowners’ Association, Inc. Despite their retirement, Domingo and Simon continued to occupy their respective housing units. They received a final notice to vacate government quarters by October 2, 1993. Subsequently, the respondent association and some members, including Domingo and Simon, filed a petition for declaratory relief with a prayer for a temporary restraining order and/or writ of preliminary injunction, which was later converted into a petition for injunction. They asserted ownership of the property based on a deed of sale and a Transfer Certificate of Title (TCT) issued in the association's name. The trial court initially denied their plea for a preliminary injunction, finding that while the land belonged to the association, the AFP owned the housing units. Procedural History: The respondents filed a petition for certiorari with the Court of Appeals (CA) after the Regional Trial Court (RTC) denied their plea for a preliminary injunction. The CA granted the petition, nullified the RTC's order, and enjoined the petitioner from evicting the respondents pending the termination of the case, provided a bond was posted. The respondents then sought clarification and restoration of their housing units, which the CA denied, stating its decision had become final. However, respondents Domingo and Simon were evicted from their units. They subsequently filed a motion in the RTC for a writ of preliminary mandatory injunction to restore them to their occupancy. The RTC granted this motion, ordering their restoration. The petitioner then filed a petition for certiorari with the CA to nullify the RTC's order. The CA dismissed this petition, affirming the RTC's order. The Petition: The petitioner filed a petition for review on certiorari with the Supreme Court, questioning whether the Court of Appeals erred in affirming the RTC's order for a writ of preliminary mandatory injunction. The petitioner argued that respondents Domingo and Simon had no right to continue occupying the units after retirement, that the association's title to the land did not divest the Republic of ownership of the housing units, and that the deed of sale was a forgery. They also contended that the association's title was subject to cancellation in a separate case and that the respondents failed to prove the requisites for a preliminary mandatory injunction. The petitioner sought the nullification of the CA's decision and the RTC's order, and the dismissal of the underlying civil case.
Issue(s)
Whether the Regional Trial Court committed grave abuse of discretion amounting to excess or lack of jurisdiction in issuing the September 4, 1996 Order granting the motion for a writ of preliminary mandatory injunction, and whether the Court of Appeals erred in affirming said order. Whether the petitioner's reliance on the Contract of Occupancy and NBI report constitutes a valid challenge to the title of the private respondents.
Ruling
The petition is denied. The assailed decision and resolution of the Court of Appeals are affirmed. No costs.
Ratio Decidendi
On the issue of grave abuse of discretion and the CA's affirmation of the RTC's order: The Supreme Court held that the trial court did not commit grave abuse of discretion. The RTC merely implemented the decision of the Court of Appeals in CA-G.R. SP No. 32502 when it issued the assailed order granting the writ of preliminary mandatory injunction. The CA's prior decision had nullified the RTC's denial of the respondents' plea for a prohibitory injunction, enjoining the petitioner from evicting the respondents pending the final disposition of the case. The appellate court reasoned that the petitioners should be heard on their complaint for injunction, and during that time, they should not be dispossessed of property titled in the name of the petitioner corporation, which held title over the land. The CA's pronouncement was intended to forestall eviction until the termination of the case. Therefore, it was a logical consequence that respondents Domingo and Simon, who were similarly situated but had been dispossessed, be restored to the status quo ante litem. To deny them restoration would render the CA's own decision nugatory. The Court emphasized that a judgment is not confined to its face but includes what is necessarily included or necessary thereto. The CA's resolution denying the motion for clarification should not be construed to foreclose the right to seek the same relief from the RTC, as preliminary mandatory injunction may be resorted to for the preservation or protection of rights during the pendency of the principal action. The legal and factual basis for the injunction had been elucidated in the CA's prior decision, justifying the RTC's order. On the petitioner's reliance on the Contract of Occupancy and NBI report: The Supreme Court found the petitioner's reliance misplaced. The contract of occupancy appended to the petition was merely an unsigned and blank printed form. Furthermore, the issue of whether the signature of Land Management Bureau Director Abelardo G. Palad, Jr. on the deed of sale was a forgery was a factual issue that needed to be resolved by the RTC in Civil Case No. 63983, which was a separate proceeding filed by the petitioner for the cancellation of the title. The Court reiterated that a certificate of title shall not be subject to collateral attack and cannot be altered, modified, or cancelled except in a direct proceeding in accordance with law, as provided under Section 48 of P.D. No. 1529. The petitioner's attempt to question the validity of the title through the present petition was deemed an impermissible collateral attack.
Main Doctrine
The Court of Appeals did not err in affirming the trial court's order granting a writ of preliminary mandatory injunction, as the trial court was merely implementing the appellate court's prior decision to maintain the status quo and allow the petitioners to be heard on their complaint for injunction, especially when the respondents were evicted despite the pendency of the case.