G.R. No. L-6434 / February 6, 1912
LUCAS REYES, SANTOS NORUNA, and JUAN ACEVEROS ROQUE, plaintiffs-appellants, vs. MGR. JEREMIAH J. HARTY, Archbishop of Manila, defendant-appellee.

FACTS

Plaintiffs Lucas Reyes, Santos Noruna, and Juan Aceveros Roque filed a complaint against the Archbishop of Manila, alleging that they leased certain lands in Malabon from parish priest Lino Cajili for six years beginning February 20, 1908. They entered possession and subleased portions. They claimed that the Archbishop, through his agents, entered the lands, surveyed them, and leased them to others, damaging the plaintiffs. Their original complaint sought a prohibitory injunction to stop these acts, damages of P3,000, and a preliminary injunction. The defendant denied the allegations, asserting Cajili lacked authority and that the lease was a conspiracy. During trial, evidence showed the defendant had already taken full possession of the lands. Plaintiffs then moved to file an amended complaint to include a claim for recovery of possession, but the trial court implicitly denied this motion by deciding the case without acting on it. Plaintiffs did not except to this denial nor assign it as error on appeal.

ISSUE

Whether the trial court erred in not granting the plaintiffs’ prayer for a preliminary injunction to restrain the defendant from acts of dispossession.

RULING

No. The Supreme Court affirmed the trial court’s judgment, holding that an injunction will not issue to restrain an act already accomplished. The evidence, presented by the plaintiffs themselves, established that the defendant was already in full and complete possession of the lands at the time of trial. Therefore, the action for a prohibitory or preliminary injunction had become moot. The Court explicitly based its decision solely on this ground to avoid prejudicing any other rights of action the plaintiffs might have regarding the lands. The Court noted that the plaintiffs abandoned their request to amend the complaint, as they took no exception to its denial and did not raise the issue on appeal.