G.R. No. 150280 . April 26, 2006.
UNIVERSITY OF THE EAST, Petitioner, vs. MARIBETH ANG WONG, Respondent.

FACTS

Respondent Maribeth Ang Wong leased canteen spaces from petitioner University of the East (UE) under contracts expiring on December 31, 1999. In December 1998, a meeting was held regarding reports of contaminated food from her canteens. Respondent alleged that during this meeting, petitioner verbally assured her of contract renewal, prompting her to spend P700,000 on renovations. Petitioner denied this, presenting meeting minutes showing no such assurance and noting renovations began months prior. In late 1999, petitioner notified respondent in writing that the leases would not be renewed.
Respondent filed an urgent petition for mandatory injunction with damages before the Manila RTC, claiming irreparable injury from non-renewal. The trial court issued a writ of preliminary injunction on January 17, 2000, upon respondent’s posting of a bond, to maintain the status quo. Petitioner’s motion for reconsideration was denied. The Court of Appeals subsequently dismissed petitioner’s certiorari petition, finding no grave abuse of discretion in the RTC’s issuance of the writ.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in issuing the writ of preliminary injunction.

RULING

The Supreme Court granted the petition, ruling that the issuance of the writ of preliminary injunction was improper. The legal logic centers on the mootness of the injunction and the absence of a clear legal right warranting such equitable relief. The lease contracts unequivocally expired on December 31, 1999. Respondent sought a two-year extension until December 31, 2001. The preliminary injunction’s sole purpose was to preserve the status quo pending resolution of her claim for renewal. By the time the Supreme Court reviewed the case, the period for the sought extension had fully lapsed, rendering the main action for mandatory injunction moot and academic. Consequently, the writ lost its legal purpose and utility.
Furthermore, the Court found respondent failed to establish a clear and positive right to the injunctive relief. Her claim relied on alleged verbal assurances of renewal, which were squarely contradicted by petitioner’s documentary evidence. The trial court’s own subsequent orders revealed respondent had accumulated massive rental arrearages, exceeding P12 million, while occupying the premises solely under the court’s writ. This indicated she was using the judicial process to avoid her contractual obligations without a substantive right to remain. Equity cannot be invoked to aid a party who does not come to court with clean hands. Therefore, the RTC’s issuance of the writ, under these circumstances, constituted an error. The Supreme Court ordered the lifting of the injunction and found respondent’s ejectment and payment of all arrears to be in order.