G.R. No. 208343, February 3, 2016
Spouses Ceferino C. Laus and Monina P. Laus, and Spouses Antonio O. Koh and Elisa T. Koh, Petitioners, vs. Optimum Security Services, Inc., Respondent.

FACTS

Petitioners, registered owners of eight parcels of land in Mabalacat, Pampanga, filed a complaint for damages with an application for a Temporary Restraining Order (TRO) and Writ of Preliminary Injunction (WPI) against respondent security agency and others. They alleged that on three occasions in August 2005, armed security guards employed by the respondent prevented them from entering their properties. They prayed for damages and for an injunction to stop the interference with their ownership rights.
Respondent opposed the application, contending that petitioners were not the real owners, as other individuals had authorized a representative to contract its security services for the properties. Respondent asserted it acted in good faith under a contractual obligation and that petitioners’ titles were under contest in a separate petition for cancellation. The Regional Trial Court (RTC) granted the WPI, finding petitioners’ evidence of registered ownership sufficient to establish a right to possession.

ISSUE

Whether the Court of Appeals erred in lifting the Writ of Preliminary Injunction and dismissing the complaint.

RULING

The Supreme Court partly granted the petition. It upheld the CA’s decision to lift the injunction but reversed the order dismissing the complaint. The Court clarified the proper purpose of a preliminary injunction. To be entitled to such a writ, a petitioner must show a clear and existing right to be protected. Where the complainant’s title or right is doubtful or contested, as when the ownership is actively disputed by another party claiming title, no clear legal right exists to warrant injunctive relief.
Here, petitioners’ titles were directly challenged by respondent’s claim that other individuals were the real owners, a claim supported by a pending petition for cancellation of title. The WPI issued by the RTC effectively transferred possession of the disputed properties to the petitioners. This was improper, as a preliminary injunction is meant to preserve the status quo ante litem (the last actual, peaceful, uncontested state before the dispute), not to alter it by delivering property from one party to another where ownership is unclear. However, the CA erred in dismissing the main complaint for damages outright. A dismissal based purely on the propriety of the ancillary injunctive relief was premature, as the complaint itself alleged a cause of action for damages arising from the alleged wrongful acts of being barred from the property. The validity of that cause of action required a full trial on the merits.