GR 159101; (July, 2011) (Digest)

FACTS

This is a Petition for Review assailing the Court of Appeals’ Decision which upheld the Regional Trial Court (RTC) Orders granting a writ of preliminary mandatory injunction. The injunction placed the respondents (the heirs of Juan Valdez and the spouses Malvar) in possession of a 103-hectare property in Antipolo City. The case originated from a Complaint for Quieting of Title filed by Manila Construction Development Corporation of the Philippines (MCDC) against the petitioners, spouses Gonzalo and Cristeta Dela Rosa. Complaints-in-intervention were filed by North East Property Ventures, Inc. (NEPVI), the spouses Valdez, and the spouses Malvar (who were grantees/assignees from the Valdez spouses).
The RTC found the following uncontroverted facts: the subject property is a 103-hectare lot; both the Dela Rosa spouses and the Valdez spouses have been in possession; several portions are occupied by others; and Transfer Certificate of Title (TCT) No. 451423-A in the name of Cristeta Dela Rosa was not recorded in the Registries of Deeds of Marikina or Antipolo.
The RTC’s evaluation of the parties’ claims revealed: MCDC’s claim was based on a Sales Patent issued to Juan Valdez, but the Deed of Absolute Sale to MCDC was unpaid and simulated. The Dela Rosas based their claim on Titulo de Propriedad No. 4136 (previously nullified by the Supreme Court) and on TCT No. 451423-A, which contained irregularities (e.g., the technical description from the Valdez Sales Patent was copied and manipulated, and its stated original registration date preceded the survey dates). NEPVI’s claim was based on a Deed of Absolute Transfer from the Valdez spouses, but it failed to show compliance with its terms. The Valdez spouses anchored their claim on a Sales Application, official receipts of payment, an Order for Issuance of Patent, and Sales Patent No. 38713 issued on September 5, 1983. The Malvar spouses derived their claim from a subsequent Deed of Absolute Transfer/Conveyance executed by the Valdez spouses.
Based on this, the RTC granted the writ of preliminary mandatory injunction in favor of the Valdez and Malvar spouses, finding they had a clear legal right to possess the property as patentees and assignees, and that the Dela Rosas’ title was dubious. The Court of Appeals affirmed, finding no grave abuse of discretion by the RTC.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s Orders granting the writ of preliminary mandatory injunction in favor of the respondents.

RULING

The Supreme Court DENIED the petition and AFFIRMED the assailed Court of Appeals Decision and Resolution. The Court held that the RTC did not commit grave abuse of discretion in issuing the writ of preliminary mandatory injunction.
The requisites for a preliminary mandatory injunction are: (1) the complainant has a clear legal right; (2) the respondent’s invasion of that right is material and substantial; and (3) there is an urgent and paramount necessity for the writ to prevent serious damage. The Court found these requisites were sufficiently established.
The Valdez spouses, as grantees of Sales Patent No. 38713, have a clear legal right to the property. A sales patent, once issued, is evidence of a state-granted title. The documents they presented (sales application, payment receipts, order of patent, and the patent itself) constituted a prima facie case of ownership. In contrast, the petitioners’ claim was weak. Their Titulo de Propriedad No. 4136 had been previously declared void by the Supreme Court. Their TCT No. 451423-A was dubious on its face (showing an earlier registration date than the survey) and, crucially, was not registered with the relevant Registries of Deeds, making it ineffective against third parties. The RTC correctly found the respondents’ right to be clear and established, while the petitioners’ claim was questionable.
The issuance of the writ was also urgent and necessary. The property was occupied by numerous parties, and the respondents were being deprived of possession. A preliminary mandatory injunction was proper to restore possession to the patentees and their assignees pending the final resolution of the main case for quieting of title. The Supreme Court found the RTC’s factual findings and conclusions to be supported by the evidence and not tainted with grave abuse of discretion. The Court of Appeals correctly affirmed the RTC’s orders. Costs were imposed against the petitioners.