Title
Source: Supreme Court
SM Investments Corp. vs. Mac Graphics Carranz International Corp.
Case
G.R. No. 224131-32
Decision Date
Jun 25, 2018
A 20-year lease between Mac Graphics and Makro was terminated over permit and insurance disputes. Courts initially granted injunctive relief, but the Supreme Court reversed, ruling Mac Graphics lacked a clear right and injuries were quantifiable, not irreparable.

Case Summary (G.R. No. 224131-32)

Facts and Antecedent Proceedings

On November 24, 2006, Mac Graphics entered into a lease agreement with Makro, designating specific billboard sites in Quezon City and Makati for advertising purposes. The lease stipulated that Mac Graphics was responsible for obtaining all necessary permits and insurance to utilize these properties. Upon a failure by Mac Graphics to secure the necessary permits, particularly from the Metro Manila Development Authority (MMDA) and comprehensive insurance, Makro unilaterally terminated the lease agreement on October 6, 2008. Mac Graphics contested this termination, asserting compliance with its obligations and citing legal grounds for remediation.

Regional Trial Court Ruling

The RTC, after reviewing the evidence and arguments from both parties, granted Mac Graphics' motion for a Writ of Preliminary Mandatory Injunction (WPMI). The court determined that Makro terminated the lease contract without allowing Mac Graphics a reasonable opportunity to remedy alleged violations, thus affirming that Mac Graphics had an existing right to the lease despite the termination.

Court of Appeals Ruling

SMIC and PMI sought to challenge the RTC’s rulings by filing petitions for certiorari in the Court of Appeals (CA), asserting that the RTC had committed grave abuse of discretion. The CA upheld the RTC's finding that Mac Graphics demonstrated sufficient legal grounds for obtaining a WPMI, maintaining that the injuries suffered by Mac Graphics could not be adequately addressed through mere monetary compensation, which led the CA to affirm the RTC’s decisions.

Supreme Court's Ruling

The Supreme Court ultimately reviewed the case and determined that the issuance of a WPMI was improper. The Court emphasized the necessity for the applicant to demonstrate a clear and unmistakable right to warrant injunctive relief. It found that because Mac Graphics’ rights were substantially contested by PMI’s defenses, a genuine doubt existe

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