G.R. No. 110929 January 20, 2000
SPS. ABELARDO & CONCHITA LOPEZ, and SPS. ANTONIO & CONCHITA MANANSALA, petitioners, vs. COURT OF APPEALS and ROBERTO VALLARTA, respondents.

FACTS

Private respondent Roberto Vallarta filed a complaint for recovery of possession, damages, and injunction against petitioners. He alleged actual, peaceful, and lawful possession of the fishpond lots since 1976, supported by a fishpond lease application with the Bureau of Fisheries and Aquatic Resources (BFAR), payment of lease rentals, and a government inspection report confirming his possession and development of the area. He claimed petitioners unlawfully entered and occupied 34 hectares of his fishpond on October 17, 1990. Petitioners countered that they have been in possession since time immemorial and had a prior labor-and-capital partnership with Vallarta. They asserted they were the rightful possessors, a claim they argued was upheld in a prior Supreme Court decision in an unrelated ejectment case against a different party. After a hearing where petitioners adopted Vallarta’s evidence without presenting their own, the Regional Trial Court granted a writ of preliminary mandatory injunction, ordering petitioners to surrender possession of the fishpond to Vallarta and later allowing Vallarta to harvest its contents.

ISSUE

Whether the trial court committed grave abuse of discretion in issuing the writ of preliminary mandatory injunction, thereby effectively transferring possession of the disputed property prior to a final judgment on the merits.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals. The issuance of the writ was proper. A preliminary mandatory injunction, while extraordinary, is justified when the complainant establishes a clear legal right to the relief demanded. The trial court’s assessment, based on the evidence presented, found that Vallarta sufficiently demonstrated a prima facie legal right to possession. This evidence included his BFAR application, lease payments, and official recognition of his possession, which petitioners failed to rebut. The Court emphasized that the grant of such injunctive relief involves a preliminary evaluation of evidence to preserve rights pending litigation, and it does not constitute a prejudgment of the main case. The findings of the trial court on these factual matters are accorded great weight and are generally not disturbed on appeal absent a clear showing of grave abuse of discretion, which was not present here. The writ was issued to prevent further irreparable injury to Vallarta’s asserted rights based on the prima facie case established during the hearing.