University of the East v. Wong
REITERATIONFacts
The Antecedents: Respondent Maribeth Ang Wong (Wong) leased canteen spaces from petitioner University of the East (UE) under contracts set to expire on December 31, 1999. In December 1998, a meeting was held regarding reports of contaminated food sold in Wong's canteens. Wong alleged UE verbally assured her of contract renewal, prompting her to spend P700,000 for renovations. UE denied this, presenting minutes of the meeting and noting renovations began before the meeting. Procedural History: UE notified Wong in writing on September 30, October 26, and November 29, 1999, that the lease contracts would not be renewed. On December 22, 1999, Wong filed a petition for mandatory injunction with damages before the Regional Trial Court (RTC), Branch 3, Manila, alleging irreparable injury. On January 17, 2000, the RTC issued a writ of preliminary injunction after Wong posted a P50,000 bond. UE's motion for reconsideration was denied. The Petition: UE filed a petition for certiorari with the Court of Appeals (CA), imputing grave abuse of discretion to the RTC for issuing the writ without showing the requisites were met. On May 31, 2001, the CA dismissed UE's petition. UE then filed the present petition for review.
Issue(s)
Whether the Court of Appeals erred in finding no grave abuse of discretion on the part of the Regional Trial Court in issuing the writ of preliminary injunction. Whether the issuance of the writ of preliminary injunction was proper despite the alleged lack of clear and positive right to injunctive relief by the respondent. Whether the case had become moot and academic due to supervening events.
Ruling
The petition is GRANTED. The resolution of the Court of Appeals is REVERSED and SET ASIDE. The writ of preliminary injunction previously issued by the Regional Trial Court is LIFTED, and the petition before the said court is DISMISSED.
Ratio Decidendi
On the propriety of the writ of preliminary injunction: The Court held that the issuance of a preliminary injunction rests entirely within the discretion of the court and is generally not interfered with except in cases of manifest abuse. However, in this case, the lease contracts expired on December 31, 1999, and respondent Wong sought a two-year extension. The writ of preliminary injunction was issued to maintain the status quo pending the determination of whether the lease contracts should be renewed. By December 31, 2001, the end of the two-year extension sought, the writ lost its usefulness. Furthermore, there was no evidence that petitioner UE ever agreed to the two-year extension. Coupled with the trial court's finding that respondent was not paying her rentals, it appeared that respondent was holding on to the leased spaces solely by virtue of the writ, not due to any agreement on renewal. The Court found it unfair that respondent was allegedly using the judicial process to circumvent her obligation to pay rentals. On the alleged lack of clear and positive right to injunctive relief: The petitioner argued that to be entitled to preliminary injunction, respondent must indubitably show a clear and positive right to injunctive relief. Respondent's action was based on alleged verbal assurances of renewal, which was controverted by documentary evidence. The Court noted that respondent's claim of verbal assurances was disputed by documentary evidence, and the renovation she claimed to have undertaken was commenced months before the alleged assurance. This lack of a clear right, combined with the fact that the lease period had expired and rentals were unpaid, weakened the basis for the injunction. On the case becoming moot and academic: The Court acknowledged that the case had become moot and academic due to a supervening event. The two-year extension of the lease prayed for by respondent had already lapsed. Consequently, the trial court itself issued an order dated July 24, 2002, lifting the writ of preliminary injunction and dismissing the petition on the ground that the relief sought had lapsed. This supervening event rendered the original issue of whether the injunction should have been issued moot, but the Court proceeded to rule on the propriety of the injunction in light of the circumstances.
Main Doctrine
A writ of preliminary injunction, issued to preserve the status quo pending determination of a lease renewal, loses its usefulness and is properly lifted when the period of the extension sought has lapsed, especially when the lessee has not paid rentals and there is no evidence of agreement to the renewal.