G.R. No. 179736 ; June 26, 2013
SPOUSES BILL AND VICTORIA HING, Petitioners, vs. ALEXANDER CHOACHUY, SR. and ALLAN CHOACHUY, Respondents.

FACTS

Petitioners, the registered owners of Lot 1900-B in Mandaue City, filed a Complaint for Injunction and Damages against respondents Alexander and Allan Choachuy. Petitioners alleged that respondents, who are stockholders of the adjacent Aldo Development & Resources, Inc. (Aldo), installed two video surveillance cameras on Aldo’s building. These cameras were directed towards petitioners’ property, capturing ongoing construction and private activities. Petitioners contended this act constituted a violation of their right to privacy. The Regional Trial Court (RTC) granted petitioners’ application for a writ of preliminary injunction, ordering respondents to remove or reposition the cameras.
Respondents filed a Petition for Certiorari with the Court of Appeals (CA), arguing the RTC committed grave abuse of discretion. The CA granted the petition, annulling the RTC’s orders. The appellate court ruled that petitioners failed to establish a clear right to the writ, noting the property was not a residence and thus the right to privacy of abode under Article 26(1) of the Civil Code was inapplicable. The CA also held respondents were improper parties, being mere stockholders of Aldo, a corporation with a separate juridical personality.

ISSUE

The core issues are: (1) whether the installation of surveillance cameras facing petitioners’ property violates their right to privacy, warranting a preliminary injunction; and (2) whether respondents, as corporate stockholders, are the proper parties to the suit.

RULING

The Supreme Court reversed the CA and reinstated the RTC’s orders granting the preliminary injunction. On the first issue, the Court held that the right to privacy is not confined to one’s residence. It encompasses the right to be free from prying eyes and unwarranted intrusion into one’s private activities, even on commercial or industrial property. The cameras, by continuously monitoring activities within petitioners’ lot, constituted an unlawful intrusion into their private sphere. This violation of privacy created a clear legal right deserving of protection through the provisional remedy of injunction to prevent a continuing wrong.
On the second issue, the Court found respondents to be proper parties. While Aldo is a separate corporate entity, the acts complained of—the installation and control of the cameras—were attributed to the respondents personally in their pleadings and by the RTC’s factual findings. The cause of action was directed against their personal acts of surveillance, not against corporate acts of Aldo. Therefore, suing them in their personal capacity did not involve piercing the corporate veil. The RTC did not commit grave abuse of discretion, as its factual findings and legal basis for issuing the injunction were well-supported.