G.R. No. 136342 ; June 15, 2000
PAUL HENDRIK P. TICZON, MICHAEL THOMAS S. PLANA, and OMNI POST, petitioners, vs. VIDEO POST MANILA, INC., respondent.

FACTS

Petitioners Paul Hendrik P. Ticzon and Michael Thomas S. Plana were former employees of respondent Video Post Manila, Inc. Their employment contracts contained Clause 5, which prohibited them from working for a competing business within two years from the termination of their employment. Both resigned in November 1995 and were subsequently hired by petitioner Omni Post, a competitor. In May 1996, respondent filed a Complaint for Damages for breach of contract and secured a Writ of Preliminary Injunction from the Regional Trial Court (RTC) on July 30, 1996, enjoining petitioners from working for Omni Post. The RTC upheld the validity of Clause 5, finding it reasonable as it was limited in duration (two years) and trade (only competing businesses).
Petitioners challenged the injunction via a Petition for Certiorari before the Court of Appeals (CA). The CA, in a Decision dated March 9, 1998, dismissed the petition as moot and academic. It reasoned that the two-year prohibitory period under Clause 5, which commenced from the petitioners’ resignation in November 1995, had already expired by the time the CA rendered its decision. The CA’s Resolution denying reconsideration was dated November 18, 1998.

ISSUE

Whether the Court of Appeals correctly dismissed the petition for certiorari assailing the Writ of Preliminary Injunction on the ground of mootness.

RULING

Yes, the Court of Appeals correctly dismissed the petition. The Supreme Court affirmed that the case had become moot and academic. The core legal principle is that courts do not adjudicate moot cases, as their duty is to settle actual controversies affecting legally demandable rights. A case becomes moot when it ceases to present a justiciable controversy due to supervening events, such as the expiration of the very obligation in dispute. Here, the preliminary injunction was issued to enforce the two-year non-competition clause in the employment contracts. The lifetime of this injunctive relief was co-terminous with the period it sought to enforce. Since the two-year period from the employees’ resignation in November 1995 had lapsed by 1997, any ruling on the validity of the injunction would have no practical legal effect. The writ had served its purpose and dissolved by operation of law. While there are exceptions to the mootness doctrine, such as when the case involves a paramount public interest or is capable of repetition yet evading review, petitioners failed to convincingly establish that such exceptions applied. Consequently, the Supreme Court upheld the CA’s dismissal, emphasizing that judicial resources should not be expended on issues that no longer require resolution.