Mabayao Farms, Inc. vs. Santos

A writ of preliminary injunction cannot bind a person who is not a party to the principal action, as an ancillary remedy affects only parties to the suit; to bind a non-party, the plaintiff must implead the non-party as an additional defendant under Section 11, Rule 3 of the Rules of Court, which allows the addition of parties at any stage of the action.

In 1969, the Bureau of Lands declared four individuals lawful possessors of Lot 1379 in Morong, Bataan. Petitioner purchased their portions in 1970 and filed a land registration application, which the trial court granted in 1991 and the Court of Appeals affirmed in 2000. In June 1997, a group of occupants entered the property, destroyed fences, and drove away petitioner's livestock.

• Land Registration: Lot 1379 consists of 144 hectares. In 1969, the Bureau of Lands declared Francisco Domingo, Reynaldo Florida, Cornelio Pilipino, and Severino Vistan lawful possessors, directing them to confirm their titles. In October 1970, petitioner bought their respective portions, totaling 69,932 square meters, and filed a land registration application (LRC Cad. Rec. No. N-209). The trial court decided the land registration case in petitioner's favor on December 20, 1991, which the Court of Appeals affirmed on March 14, 2000.
• Injunction Suit: In June 1997, occupants entered the land, destroyed fences, and drove away petitioner's livestock. On October 9, 1997, petitioner filed an injunction complaint with the RTC of Balanga, Bataan (Civil Case No. 6695) against Juanito Infante, Domingo Infante, Lito Mangalidan, Jaime Aquino, and unnamed "Does." When the sheriff served the temporary restraining order, five persons found cultivating the land refused to identify themselves, claiming they were farm workers of Antonio Santos.
• CA Petition: The trial court issued a writ of preliminary injunction on April 14, 1998, enjoining the defendants or persons acting in their stead from entering and cultivating the land. The writ was served upon private respondent Antonio Santos. On February 24, 1999, Santos filed a petition for certiorari with the Court of Appeals, claiming he purchased the property from the heirs of Toribio Alejandro, was not a party to Civil Case No. 6695, and only learned of the injunction on February 16, 1999. The Court of Appeals granted his petition, prompting the elevation to the Supreme Court.

• Binding Effect of the Writ: Petitioner argued that the "Does" in the complaint included private respondent, and because he was personally served with the injunctive order on June 5, 1998, he was forewarned to intervene in Civil Case No. 6695. His failure to intervene precludes him from claiming deprivation of due process.
• Impleading vs. Intervention: Petitioner maintained that the Court of Appeals erred in advising impleader under Section 11, Rule 3 of the Rules of Court. Because petitioner had already rested its case, it was too late to amend the complaint, and private respondent should have intervened to protect his rights instead.

• Due Process: Respondent countered that he was not a party to Civil Case No. 6695 and had no legal duty to file pleadings or protest the writ therein. Enforcing the injunction against a stranger violated his fundamental rights to notice and hearing.
• Impleading vs. Intervention: Respondent argued that Section 11, Rule 3 applies because no final judgment had been rendered in the main case, making his inclusion as a defendant procedurally correct. Petitioner cannot insist that a stranger must be vigilant in intervening to protect his rights.

• Binding Effect of Injunction: Whether a writ of preliminary injunction issued in a civil case can bind a person who is not a party to the action.
• Proper Remedy for Non-Party: Whether a non-party must intervene in the main suit to protect his rights, or whether the plaintiff must implead the non-party as an additional defendant under Section 11, Rule 3 of the Rules of Court.

• Binding Effect of Injunction: The writ cannot bind private respondent. A preliminary injunction is an ancillary or preventive remedy, adjunct to a main suit, designed to preserve the status quo pending final judgment. A person who is not a party to the principal action cannot be bound by an ancillary writ. The order specifically enjoined the defendants or persons acting in their stead; private respondent was not a defendant, was not a trespasser at the time the suit was instituted, and was not acting on behalf of the defendants.
• Proper Remedy for Non-Party: The plaintiff must implead the non-party as an additional defendant. Intervention is permissive, not compulsory; a stranger has no duty to intervene. Moreover, private respondent lacked the requisite legal interest to intervene in an action for injunction and damages where he was a stranger, and allowing intervention would have unnecessarily complicated the case. Section 11, Rule 3 expressly allows the addition of parties at any stage of the action, negating petitioner's claim that it was too late to amend the complaint.

• Ancillary Nature of Preliminary Injunction — A preliminary injunction is a provisional remedy, adjunct to a main suit, aimed at preserving the status quo pending final judgment. It is not a cause of action in itself. Consequently, a person who is not a party to the main suit cannot be bound by the ancillary writ, nor affected by any proceeding to which he is a stranger.
• Permissive Nature of Intervention — Intervention in an action is neither compulsory nor mandatory but only optional and permissive. A stranger to a case cannot be compelled to intervene to protect rights from an improperly extended injunction.
• Requisites of Intervention — Two requisites must concur for intervention to be allowed: (a) the movant has a legal interest in the matter in litigation, and (b) intervention must not unduly delay or prejudice the adjudication of the rights of the parties, nor should the claim of the intervenor be capable of being properly decided in a separate proceeding. The interest must be of such direct and immediate character that the intervenor will gain or lose by the direct legal operation and effect of the judgment.

• "A preliminary injunction is an order granted at any stage of an action prior to final judgment, requiring a person to refrain from a particular act. ... Thus, a person who is not a party in the main suit... cannot be bound by an ancillary writ, such as the writ of preliminary injunction issued against the defendants in Civil Case No. 6695. He cannot be affected by any proceeding to which he is a stranger."
• "Intervention in an action is neither compulsory nor mandatory but only optional and permissive."

• China Banking Corporation v. Court of Appeals — Cited for the definition of preliminary injunction as an ancillary or preventive remedy.
• Matuguina Integrated Wood Products, Inc. v. Court of Appeals — Cited for the principle that a person not a party to the main suit cannot be bound by an ancillary writ.
• Cruzcosa, et al. v. Hon. H. Concepcion, et al. — Cited for the principle that intervention is optional and permissive, not compulsory.
• Garcia v. David — Cited for the definition of legal interest required for intervention, which must be of such direct and immediate character that the intervenor will gain or lose by the direct legal operation and effect of the judgment.

• Rule 58, Section 1, 1997 Rules of Civil Procedure — Defines preliminary injunction as an order granted at any stage of an action prior to final judgment, requiring a person to refrain from a particular act. Applied to characterize the writ as an ancillary remedy that cannot bind strangers to the suit.
• Rule 3, Section 11, 1997 Rules of Civil Procedure — Governs misjoinder and non-joinder of parties, allowing parties to be dropped or added by order of the court on motion of any party or on its own initiative at any stage of the action. Applied to establish that petitioner should have impleaded private respondent as an additional defendant rather than expecting him to intervene.

Bellosillo, Mendoza, and Corona, JJ.