Purisimo Buyco v. Nelson Baraquia

Summary

Baraquia sought to establish permanent right of way through Buyco's property to access his poultry farm. RTC granted preliminary injunction but dismissed the main complaint for failure to prove requisites for easement under Civil Code Articles 649-650. When Buyco closed the road after dismissal, contempt proceedings ensued. The Supreme Court resolved whether preliminary injunction remains valid pending appeal of dismissal. The Court held that preliminary injunctions are automatically dissolved upon dismissal of the main action, regardless of pending appeal, as the provisional remedy's purpose is served once the case is decided. The decision clarifies that appeals from dismissals do not suspend the judgment, distinguishing cases where incidents are appealed versus cases dismissed on the merits.