GR 108921; (April, 2000) (Digest)
March 16, 2026GR 145915; (April, 2003) (Digest)
March 16, 2026G.R. No. 95522; February 7, 1991
WHITE PLAINS ASSOCIATION, INC., petitioner, vs. HON. GODOFREDO L. LEGASPI, in his capacity as Presiding Judge of RTC, Quezon City, Branch 79, QUEZON CITY DEVELOPMENT AND FINANCING CORPORATION, HON. FIORELLO ESTUAR, in his capacity as Secretary of Public Works and Highways, HON. CONRADO DANGANAN, in his capacity as District Engineer of Quezon City, SPRAGUE CONSTRUCTION and M.E. APO CONSTRUCTION, respondents.
FACTS
The core dispute involves the widening of Katipunan Road within the White Plains Subdivision. The subdivision developer, respondent Quezon City Development and Financing Corporation (QCDFC), originally allocated a 38-meter wide road lot but developed only 20 meters. In a prior case (G.R. No. 55868), the Supreme Court definitively ruled that the entire 38-meter road lot, including the undeveloped 18-meter portion, was dedicated for public use. The Court ordered the cancellation of QCDFC’s titles over the disputed portion and the reinstatement of the original title with its annotation for public road reservation, a judgment which became final in 1986.
Subsequently, in 1989, the government allocated funds to widen the road. QCDFC, claiming ownership, filed a new complaint for injunction in the Regional Trial Court to stop the widening project. The trial court initially dissolved a preliminary injunction but later reinstated it, prompting the petitioner association and other public respondents to file this certiorari petition.
ISSUE
Whether the Regional Trial Court committed grave abuse of discretion in issuing and maintaining a writ of preliminary injunction to halt the road widening project.
RULING
Yes. The Supreme Court granted the petition, annulling the trial court’s orders. The legal logic is anchored on the conclusive finality of the decision in G.R. No. 55868, which established that the disputed 18-meter strip was part of a road lot withdrawn from commerce and dedicated for public use. This prior judgment constitutes res judicata, barring QCDFC from re-litigating its claim of ownership in a new action for injunction. As the dedicated road lot, ownership is vested in the government, and QCDFC’s obligation was to develop and donate it. The government’s decision to fund the widening itself relieved QCDFC of the development cost. Therefore, QCDFC has no legal right to demand compensation or to obstruct the public project. The trial court’s injunction, which disregarded the final and executory ruling of the Supreme Court, was a patent grave abuse of discretion. The Court directed QCDFC to execute a deed of donation for the land to the Quezon City government.
