G.R. No. 213753 , November 10, 2020
ARMED FORCES OF THE PHILIPPINES, PETITIONER, VS. ENELINDA AMOGOD, ET AL., RESPONDENTS.

FACTS

On May 7, 2007, and June 27, 2007, two groups of respondents, actual occupants of various parcels of land in Cagayan de Oro City (Lots 2, 3, 4, 5, and 6), filed separate petitions for injunction (Civil Case Nos. 2007-104 and 2007-152) against the petitioner, the Armed Forces of the Philippines (AFP), Fourth Infantry Division, Philippine Army, Camp Edilberto Evangelista. The respondents averred that they and their predecessors-in-interest had been lawful occupants of the subject lands for more than 30 years; that their lands were outside the 32-hectare Camp Edilberto Evangelista given to the AFP by the Velezes; and that they had, as early as 1995, petitioned the President for the segregation and release of these lands. In 2007, after receiving a notice to vacate from the AFP and refusing to comply, respondents alleged they were harassed and had some stores closed, prompting them to seek an injunction to stop these actions and protect their peaceful possession.
The AFP, in its answer with counterclaim, contended that the respondents were squatters on a military reservation and thus considered nuisances per se subject to summary abatement. It claimed lawful ownership of the subject lands by virtue of a 1936 sale from Apolinar Velez, later acknowledged in deeds of donation and quitclaim from the Velezes and Pinedas.
The Regional Trial Court (RTC) granted the petitions for injunction in an Order dated October 29, 2008. It relied on a relocation/verification report by Engr. Arlene Galope and a supplemental report from DENR Director Dichoso, which concluded that the subject parcels were not only outside the AFP’s 36-hectare property but were also alienable and disposable land. The RTC held that respondents, being in actual possession since time immemorial, had a clear right that must be protected, and it ordered the AFP to cease eviction efforts, harassment, and to reopen closed stores.
The Court of Appeals (CA), in a Decision dated August 22, 2013, affirmed the RTC Order. The CA based its decision mainly on a September 21, 2010 Order from the DENR Regional Executive Director (RED) of Region X, which granted the respondents’ petition for exclusion and segregation, finding the subject lots to be outside the military camp’s titled property. The CA denied the AFP’s motion for reconsideration in a Resolution dated July 30, 2014. The AFP then elevated the case to the Supreme Court via a petition for review.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s grant of the writ of injunction in favor of the respondents.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision and Resolution of the Court of Appeals. The Court held that the CA correctly affirmed the RTC’s grant of the injunction.
The Court found that the respondents had established a clear and unmistakable right to the possession of the subject properties, which is a requisite for the issuance of a writ of injunction. This right was substantiated by the findings of the DENR, through its RED, which, after evaluation of evidence and ocular inspection, officially declared that the subject lots were outside the titled property of Camp Edilberto Evangelista and were alienable and disposable. This administrative finding, which was not appealed by the AFP, attained finality and conclusively established that the respondents were not squatters on a military reservation.
Consequently, the AFP’s claim of ownership and its actions to evict the respondents based on the premise that the land was part of the military camp lost factual and legal basis. The respondents’ possession, having been shown to be on land not owned by the AFP, was lawful and entitled to protection. The AFP’s acts of harassment and summary eviction, therefore, constituted a violation of the respondents’ rights which the injunctive writ properly sought to prevent.
The Supreme Court emphasized that the purpose of a preliminary injunction is to preserve the status quo ante litem, which in this case meant maintaining the respondents’ peaceful possession pending the final resolution of the underlying issue of ownership. Since the respondents demonstrated a clear legal right (possession of land declared alienable and outside the military camp) and a material and substantial invasion of that right by the AFP’s eviction efforts, the grant of the injunction was proper. The Court found no reversible error in the CA’s decision affirming the RTC.