Spouses Laus v. Optimum Security Services

Facts:

Petitioners filed a complaint for "Damages with Application for a TRO and WPI," against respondent, several security guards employed by it, including Marivalles and Olivette, and TIPCO. Petitioners alleged that on three (3) separate occasions in August 2005, they were prevented by armed security guards working for respondent and TIPCO from entering the eight (8) parcels of land in Mabalacat, Pampanga belonging to them.

Opposing petitioners' application for TRO and WPI, respondent and Marivalles countered that petitioners are not entitled to the TRO and WPI prayed for because they do not own the subject properties. They maintained that Margarita dela Rosa, Manuel dela Pena, Michael Pineda, Fermin Dizon, William Lee, and Odon Sibug are the real owners thereof, who authorized Mr. Ranilo M. Arceo (Mr. Arceo) to enter into the Security Service Contract with respondent to secure the subject properties. Moreover, they claimed that the signatures appearing on the Deeds of Sale were forged and, in fact, a petition for cancellation of petitioners' titles was filed by Jose Bermudo, one of the original holders of the emancipation patent over three (3) parcels of land in the subject properties, which was still pending before another court.

TIPCO denied preventing petitioners from entering the subject properties. It pointed out that it did not claim ownership or possession thereof, and, as such, did not hire the armed security guards who prevented petitioners from entering the subject properties.

RTC ruled in favor of petitioners. Respondent and TIPCO separately moved for reconsideration but were denied. Respondent elevated the case to the CA which reversed the RTC ruling. Petitioners filed for an MR but was denied.

Issue:

Whether or not respondent is a real party in interest

Held:

In this case, while the alleged real owners of the subject properties may be considered as real parties in interest for the reason that their supposed rights over these properties stand to be prejudiced, they are not indispensable parties to the instant suit. Despite its denomination as an action for "damages' in the complaint's caption, the action, as may be gleaned from the pleading's allegations, is really one for injunction as it ultimately seeks to permanently enjoin respondent and the other defendants, from restricting petitioners' access to the subject properties. The crux of the main case, therefore, is whether or not respondent and said defendants were justified in preventing petitioners from conducting the relocation survey on the subject properties. Damages are also sought as ancillary relief for the acts complained of. These issues can be resolved independent of the participation of the alleged real owners of the subject properties. Hence, they are not indispensable parties, without whom no final determination can be had.

In view of the nature of the case as above-explained, respondent and the other defendants are real parties in interest. Clearly, they stand to be directly injured by an adverse judgment. They are the parties against whom the prayed for injunction is directed and are also alleged to be liable for the resultant damage.