G.R. No. 112172; November 20, 2000
PUBLIC ESTATES AUTHORITY, RICARDO PEÑA AND RAMON AURELLANO, JR., petitioners, vs. HON. COURT OF APPEALS, HON. OMAR U. AMIN, in his capacity as PRESIDING JUDGE, Branch 135, Regional Trial Court of Makati, and BERNARDO DE LEON, respondents.

FACTS

The Public Estates Authority (PEA) initiated the construction of the R-1 Toll Expressway as part of the Manila-Cavite Coastal Road Reclamation Project. PEA claimed that Lot 5155, situated within the project area, was formerly underwater and part of a salvage zone until its reclamation in 1982. In December 1992, PEA discovered that respondent Bernardo de Leon had begun constructing bunkhouses and fencing on the lot. De Leon asserted a claim of ownership, stating his father had possessed the land for over fifty years and that he and his siblings inherited this possession. When PEA security personnel, through a directive, demanded he vacate and subsequently demolished the structures in January 1993, de Leon filed a complaint for damages with a prayer for a preliminary injunction.
The Regional Trial Court granted a writ of preliminary injunction, finding that de Leon had established a legal right over the lot by preponderance of evidence, including a cadastral map and tax declarations, and would suffer irreparable injury. The Court of Appeals affirmed this decision. PEA elevated the case to the Supreme Court via certiorari, arguing that de Leon failed to prove a clear legal right warranting injunctive relief.

ISSUE

Whether respondent Bernardo de Leon possessed a clear legal right to Lot 5155, based on his claim of possession and documentary evidence, sufficient to justify the issuance of a writ of preliminary injunction against the petitioners.

RULING

The Supreme Court reversed the decisions of the lower courts and dismissed the complaint. The Court held that a preliminary injunction requires a clear and unmistakable right to be protected. De Leon’s claim, based on possession and documents like a cadastral map and tax declarations, was insufficient to establish such a right over alienable public land.
The legal logic is anchored on the Regalian doctrine and the Public Land Act. The Court reiterated that all lands of the public domain belong to the State. Occupation and possession, no matter how long, cannot ripen into ownership unless the land is officially classified as alienable and disposable, and a grant is procured from the government. De Leon’s evidence did not constitute a title or proof of an official grant. A cadastral map is merely a survey identifier, and tax declarations are not conclusive evidence of ownership. His claim of possession, even if assumed to be true, only constituted a mere claim of ownership, not a recognized legal right enforceable by injunction. Since no clear right was established, the injunction was improperly issued. The Court emphasized that injunctions cannot be used to take property out of the possession of one party and deliver it to another whose title is questionable, especially when a government infrastructure project is involved.