# Non-Competes in the Philippines[^about]

The Philippines has no non-compete statute; a post-employment restraint is enforceable only if it is reasonable — limited as to time, trade, and place, tied to a legitimate business interest, and not contrary to public policy — and a suit to enforce one is a civil case for the regular courts, not the labor tribunals.

## Are non-competes enforceable in the Philippines? {#employee-noncompetes}

**Short answer.** Yes, if they are reasonable. The Philippines has no statute that governs non-competes, and it is not a per se ban jurisdiction. A post-employment non-compete or *non-involvement* clause is enforced under the Civil Code's freedom-to-contract principle — provided the stipulation is not contrary to law, morals, good customs, public order, or public policy [^civilcode-1306]. Within that limit a restraint is valid as long as it carries reasonable limitations as to time, trade, and place [^tiu-time-trade-place].

This puts the Philippines in the middle of the global map. It is not California or North Dakota, where an employee non-compete is void no matter how narrowly drawn, and it is not India, where post-employment restraints are categorically unenforceable. It is a reasonableness jurisdiction whose rules are largely judge-made, built on top of the Civil Code's presumption that a freely negotiated contract has the force of law between the parties.

"Not being contrary to public policy, the non-involvement clause, which petitioner and respondent freely agreed upon, has the force of law between them, and thus, should be complied with in good faith."[^tiu-force-of-law]

The Supreme Court's 2007 decision in *Tiu v. Platinum Plans Phil., Inc.* is the leading modern authority. It confirms that a non-involvement clause is not automatically void as a restraint of trade, and that once a reasonable clause survives scrutiny the courts will enforce it according to its terms.

## What makes a non-compete reasonable in the Philippines? {#reasonableness-test}

**Short answer.** Reasonableness is decided clause by clause against a five-factor test. In *Rivera v. Solidbank Corp.*, the Supreme Court directed trial courts to weigh whether the covenant protects a legitimate business interest, whether it unduly burdens the employee, whether it harms the public welfare, whether its time and territorial limits are reasonable, and whether it is reasonable as a matter of public policy [^rivera-five-factors]. A restraint that flunks any of these — most classically one that is *not limited as to trade* — is void as against public policy [^ferrazzini-not-trade].

The five factors are not a checklist with numeric thresholds; they are a structured way of asking the older question the Court has posed since 1916 — whether the restraint goes further than the employer's legitimate interest requires. The foundational case, *Ferrazzini v. Gsell*, struck down a clause barring a discharged foreman from *any* employment anywhere in the Philippine Islands for five years, holding it an unreasonable restraint precisely because it was bounded in time and space but left the employee no trade to practise.

"The contract under consideration, tested by the law, rules and principles above set forth, is clearly one in undue or unreasonable restraint of trade and therefore against public policy. It is limited as to time and space but not as to trade."[^ferrazzini-not-trade]

Because reasonableness turns on the facts, it is generally not a question a court can resolve on the pleadings. In *Rivera* itself the Supreme Court set aside a summary judgment, holding that the trial court had foreclosed the evidence needed to decide whether the covenant was reasonable [^rivera-summary-judgment].

## How long and how wide can a Philippine non-compete be? {#duration-geography}

**Short answer.** There is no statutory limit, but the durations the Supreme Court has actually upheld are short. In *Tiu*, a two-year non-involvement clause confined to the employer's pre-need industry was held reasonable [^tiu-two-year]. Geography matters too: the Court has said a territorial limitation is necessary so the employee knows what counts as a violation and so the restraint tracks where the employer actually does business [^rivera-territorial].

A covenant does not need to limit *both* time and place to survive; a reasonable limitation on either dimension can be enough, as the Court held in 1924 in *Del Castillo v. Richmond* when it upheld a restriction on a pharmacist opening a competing drugstore in the same locality [^delcastillo-time-or-place]. But the absence of any geographic boundary is a serious weakness. In *Rivera*, a one-year ban on joining any competitor bank — with no territorial limit at all — was treated as suspect on its face and could not be enforced without evidence justifying so broad a sweep.

"A provision on territorial limitation is necessary to guide an employee of what constitutes as violation of a restrictive covenant and whether the geographic scope is co-extensive with that in which the employer is doing business."[^rivera-territorial]

The practical takeaway is that a defensible Philippine covenant looks narrow: a year or two, confined to the employer's actual line of business, and tied to a market where the employer competes — not an open-ended bar on working anywhere for anyone.

## What interest must a Philippine non-compete protect? {#legitimate-interest}

**Short answer.** A legitimate business interest — typically confidential strategies, trade secrets, or goodwill the employee was trusted with. The first *Rivera* factor asks exactly that: whether the covenant protects a legitimate business interest of the employer [^q4-rivera-interest]. *Tiu* shows what qualifies: the clause there was upheld because the employee was a senior executive who would otherwise carry the employer's sensitive, industry-specific knowledge straight to a direct competitor [^q4-tiu-trade].

The line the courts police is between protecting an asset and merely suppressing a competitor. A restraint built around genuinely confidential information, key client relationships, or specialised training the employer paid for stands on firm ground. A bare desire to keep a former employee out of the market does not. That is also why a confidentiality or non-disclosure obligation — which restricts only the misuse of information, not the right to work — is the most durable protection an employer has, while a blanket bar on competing is the most exposed.

> [!CAUTION]
> **Drafting note.**
>
> Anchor the covenant to a specific protectable interest — the confidential strategy, trade secret, or client goodwill the employee actually handled — rather than barring competition in the abstract. A clause framed around a real interest and confined to the employer's line of business is what carried the day in *Tiu*; an untethered ban on working for a competitor is the weakest position [^q4-tiu-trade].

## Can a Philippine court narrow an overbroad non-compete? {#court-narrowing}

**Short answer.** There is no established practice of doing so. When the Supreme Court has found a restraint unreasonable, it has treated the covenant as void against public policy — as it did with the five-year, all-trades ban in *Ferrazzini* [^q5-ferrazzini-void] — rather than rewriting it to a reasonable scope. No decision squarely holds whether a Philippine court may instead narrow an overbroad covenant, and the courts have not adopted the judicial-reformation or read-down approach used in some United States states. The safe assumption is therefore that an overbroad clause fails entirely rather than being trimmed.

The drafting consequence is the same one that follows from the reasonableness test: each restriction has to be defensible on its own terms, because there is no settled doctrine for a court to salvage an aggressive clause by narrowing it. What a court *can* adjust is the money side. Under the Civil Code a court may equitably reduce a stipulated penalty when it is iniquitous or unconscionable, but in *Tiu* the Court refused to reduce the agreed liquidated damages because the employee had shown no good-faith intention to comply [^q5-tiu-goodfaith].

> [!CAUTION]
> **Drafting note.**
>
> Do not draft a deliberately broad non-compete in the hope a court will pare it back. A restraint the Supreme Court has found unreasonable was struck down as contrary to public policy, and no decision establishes that a court will instead narrow an overbroad covenant [^q5-ferrazzini-void], so calibrate the time, trade, and territory to what you can defend as reasonable from the outset.

## Which court hears a Philippine non-compete dispute? {#which-court}

**Short answer.** The regular civil courts, not the labor tribunals — when the breach is post-employment. A suit to recover damages for breaching a post-employment non-compete is a civil-law action over which the regular courts, not the Labor Arbiter or the NLRC, have jurisdiction [^daichi-civil]. The Supreme Court has reaffirmed this repeatedly: the covenant takes effect only after the employment relationship ends, so the claim sounds in contract, not labor law [^portillo-civil].

This is a recurring trap for employers who assume that anything in an employment contract belongs before the NLRC. It does not. In *Dai-Chi Electronics v. Villarama* and again in *Yusen Air and Sea Service v. Villamor*, the Court routed post-employment non-compete damage claims to the regular courts because they concern the parties' post-employment relations [^yusen-civil].

A related consequence is that the employer cannot help itself to the employee's pay. In *Portillo v. Rudolf Lietz, Inc.*, the Court held there was no causal connection between an employee's claim for unpaid wages and the employer's claim for liquidated damages under a goodwill clause, so the two could not be set off against each other [^portillo-no-setoff]. The employer must release the final pay and pursue the non-compete claim as a separate civil action.

"Such cause of action is within the realm of Civil Law, and jurisdiction over the controversy belongs to the regular courts. More so when we consider that the stipulation refers to the post-employment relations of the parties."[^daichi-civil]

> [!NOTE]
> **Practice note.**
>
> Do not withhold a departing employee's final pay to offset a suspected non-compete breach. Unpaid wages and a liquidated-damages claim arise in different fora with no causal connection between them, so they cannot be set off [^portillo-no-setoff]; release the pay and file the non-compete claim separately in the regular courts.

## What if the employee competed while still employed? {#during-employment}

**Short answer.** That changes the analysis. A restraint that operates *during* employment is backed by the employee's duty of loyalty, and the labor tribunals can enforce it as part of a compensation dispute. In *Century Properties v. Babiano*, the Supreme Court upheld the forfeiture of a sales executive's unpaid commissions because he accepted a position with a direct competitor while still employed — a breach of the contract's confidentiality and non-compete clause [^century-violation].

The distinction is timing, not labels. *Portillo* keeps post-employment non-compete claims in the regular courts; *Century Properties* shows that when the disloyal competition happens before the employee resigns, an express forfeiture clause can be applied against the unpaid commissions and incentives it covers, within the labor proceeding itself. The clause there spelled out the consequence in plain terms [^century-forfeiture].

"Irrefragably, this is a glaring violation of the ‘Confidentiality of Documents and Non-Compete Clause’ in his employment contract with CPI, thus, justifying the forfeiture of his unpaid commissions."[^century-violation]

## Do non-competes apply to independent contractors in the Philippines? {#contractors}

**Short answer.** Yes. When the restrained party is an independent contractor rather than an employee, the dispute is handled as an ordinary civil action under the freedom-to-contract principle rather than as a labor case. In *Consulta v. Court of Appeals*, once the Supreme Court found that the managing associate was an independent agent and not an employee, it upheld her one-year exclusivity restriction as a reasonable restriction designed to protect the company's business interest [^consulta-reasonable].

The threshold question is status. In *Consulta* the Court held that the managing associate was an independent agent, not an employee [^consulta-status], so the dispute fell to the regular courts as an ordinary civil matter rather than to the labor tribunals. The restriction was also narrow — it barred only competing activity, leaving the associate free to take on non-competing business — and that tailoring is what made it reasonable. *Consulta* is best read for that status point rather than as announcing a separate, more lenient standard for contractor covenants: the later *Tiu* decision cites it under the same time-trade-place reasonableness test applied to employees.

## How is a Philippine non-compete enforced? {#remedies}

**Short answer.** By injunction and by damages, including liquidated damages. A continuing breach of a valid negative covenant can be restrained by injunction, because the ongoing harm cannot be adequately repaired through an ordinary damages suit [^ollendorff-injunction]. To avoid having to prove actual loss, employers typically attach a penal clause; under the Civil Code such a penalty substitutes for damages on breach [^civilcode-1226].

Injunctive relief has a built-in expiry, though. Once the restraint period itself lapses, a suit for an injunction becomes moot — although a claim for damages already incurred survives [^yusen-moot]. That is one reason liquidated-damages clauses are common: they remain enforceable after the covenant period ends and spare the employer the difficult task of quantifying lost business. As covered above, the courts will enforce a reasonable stipulated penalty, equitably reducing it only in the limited cases the Civil Code allows.

"With respect to the contention that an injunction may only be granted to prevent irreparable injury, the answer is that any continuing breach of a valid negative covenant is irreparable by the ordinary process of courts of law."[^ollendorff-injunction]

## Is garden leave allowed in the Philippines? {#garden-leave}

**Short answer.** Yes. The Supreme Court has said there is no prohibition under Philippine labor law against a garden-leave clause in an employment contract [^mejila-garden-leave]. Because garden leave keeps the employee on the payroll and bound by the duty of loyalty during the notice period, it is a useful — and lower-risk — alternative to a post-employment restraint, which must instead run the full reasonableness gauntlet.

Garden leave operates while the employment relationship still exists, so it does not depend on the restraint-of-trade analysis that governs post-termination covenants. For an employer worried about a departing employee's access to live information, paying the employee through a notice period can protect the business without the enforceability risk that attaches to a non-compete that bites after the job ends.

"There is no prohibition under our labor laws against a garden leave clause in an employment contract."[^mejila-garden-leave]

## Does a Philippine non-compete pause or extend if the employee breaches? {#tolling}

**Short answer.** The Supreme Court has not addressed it. No Philippine decision holds that the restraint period tolls — pauses and then resumes — while a former employee is in breach or while litigation runs, so a clause that purports to extend the covenant by the length of any breach is untested. An employer should treat the stated period as the maximum and not assume the clock stops while the employee competes.

This open question sits in tension with a principle the Court *has* stated. *Rivera* requires a covenant to be drawn so the employee can tell with certainty what counts as a violation and how far the restraint reaches [^q11-rivera-certainty]. An automatic extension-on-breach provision cuts the other way: it leaves the end date contingent on contested conduct, which is exactly the kind of uncertainty the Court has warned against. Until there is direct authority, the safer course is a fixed, defensible period rather than a self-extending one.

> [!CAUTION]
> **Drafting note.**
>
> Do not rely on a clause that extends the non-compete by the length of any breach. No Philippine authority validates tolling of the restraint period, and an open-ended end date is in tension with the requirement that the employee be able to tell with certainty what the covenant forbids [^q11-rivera-certainty]. Treat the stated duration as the ceiling.

## Is a non-compete statute coming in the Philippines? {#statutory-outlook}

**Short answer.** Not as of June 2026. There is no Philippine statute that bans or specifically regulates employee non-competes; enforceability still turns entirely on the Civil Code and the Supreme Court's reasonableness jurisprudence. The constitutional backdrop reinforces that scrutiny — the 1987 Constitution declares that no combinations in restraint of trade or unfair competition shall be allowed [^consti-art12] — but it is applied as a public-policy lens on contracts, not as a self-executing ban on covenants.

Reform of employee non-competes has been a topic of legislative and practitioner discussion, mirroring debates abroad, but no bill specifically regulating them has been enacted or has materially advanced as of June 2026. Until that changes, the framework set out in this note governs, and the Constitution's anti-restraint-of-trade policy functions mainly to sharpen the courts' review of overbroad covenants rather than to supply a fixed rule.

> [!NOTE]
> **Practice note.**
>
> Do not draft to an anticipated Philippine non-compete statute. None is in force as of June 2026, so enforceability still rests entirely on the Civil Code and the courts' reasonableness test, read against the Constitution's policy that no combinations in restraint of trade shall be allowed [^consti-art12].



[^about]: By Steven Obiajulu, J.D. Published by [openagreements.org](https://openagreements.org). Last reviewed 2026-06-03. License: CC BY 4.0. Steven Obiajulu, J.D. is not admitted to practise law in Philippines. This article summarizes publicly available Philippines legal sources for general information only — it is not legal advice and does not create a lawyer–client relationship. It may not reflect the most recent legal developments and is provided without warranty as to accuracy or completeness; verify against the primary sources cited and consult a locally qualified lawyer before relying on it.

[^civilcode-1306]: **Civil Code of the Philippines (RA 386), Art. 1306** — "Article 1306. The contracting parties may establish such stipulations, clauses, terms and conditions as they may deem convenient, provided they are not contrary to law, morals, good customs, public order, or public policy." *Civil Code of the Philippines, Republic Act No. 386, Art. 1306.* <https://lawphil.net/statutes/repacts/ra1949/ra_386_1949.html>

[^tiu-time-trade-place]: **Tiu v. Platinum Plans Phil., Inc.** — "Conformably then with the aforementioned pronouncements, a non-involvement clause is not necessarily void for being in restraint of trade as long as there are reasonable limitations as to time, trade, and place." *Tiu v. Platinum Plans Phil., Inc., G.R. No. 163512, Feb. 28, 2007.* <https://lawphil.net/judjuris/juri2007/feb2007/gr_163512_2007.html>

[^tiu-force-of-law]: **Tiu v. Platinum Plans Phil., Inc.** — "Not being contrary to public policy, the non-involvement clause, which petitioner and respondent freely agreed upon, has the force of law between them, and thus, should be complied with in good faith." *Tiu v. Platinum Plans Phil., Inc., G.R. No. 163512, Feb. 28, 2007.* <https://lawphil.net/judjuris/juri2007/feb2007/gr_163512_2007.html>

[^rivera-five-factors]: **Rivera v. Solidbank Corp.** — "Thus, in determining whether the contract is reasonable or not, the trial court should consider the following factors: (a) whether the covenant protects a legitimate business interest of the employer; (b) whether the covenant creates an undue burden on the employee; (c) whether the covenant is injurious to the public welfare; (d) whether the time and territorial limitations contained in the covenant are reasonable; and (e) whether the restraint is reasonable from the standpoint of public policy." *Rivera v. Solidbank Corp., G.R. No. 163269, Apr. 19, 2006.* <https://lawphil.net/judjuris/juri2006/apr2006/gr_163269_2006.html>

[^ferrazzini-not-trade]: **Ferrazzini v. Gsell** — "The contract under consideration, tested by the law, rules and principles above set forth, is clearly one in undue or unreasonable restraint of trade and therefore against public policy. It is limited as to time and space but not as to trade." *Ferrazzini v. Gsell, G.R. No. L-10712, Aug. 10, 1916.* <https://lawphil.net/judjuris/juri1916/aug1916/gr_l-10712_1916.html>

[^rivera-summary-judgment]: **Rivera v. Solidbank Corp.** — "There is no factual basis for the trial court's ruling, for the simple reason that it rendered summary judgment and thereby foreclosed the presentation of evidence by the parties to prove whether the restrictive covenant is reasonable or not." *Rivera v. Solidbank Corp., G.R. No. 163269, Apr. 19, 2006.* <https://lawphil.net/judjuris/juri2006/apr2006/gr_163269_2006.html>

[^tiu-two-year]: **Tiu v. Platinum Plans Phil., Inc.** — "In this case, the non-involvement clause has a time limit: two years from the time petitioner's employment with respondent ends." *Tiu v. Platinum Plans Phil., Inc., G.R. No. 163512, Feb. 28, 2007.* <https://lawphil.net/judjuris/juri2007/feb2007/gr_163512_2007.html>

[^rivera-territorial]: **Rivera v. Solidbank Corp.** — "A provision on territorial limitation is necessary to guide an employee of what constitutes as violation of a restrictive covenant and whether the geographic scope is co-extensive with that in which the employer is doing business." *Rivera v. Solidbank Corp., G.R. No. 163269, Apr. 19, 2006.* <https://lawphil.net/judjuris/juri2006/apr2006/gr_163269_2006.html>

[^delcastillo-time-or-place]: **Del Castillo v. Richmond** — "Later cases, and we think the rule is now well established, have held that a contract in restraint of trade is valid providing there is a limitation upon either time or place." *Del Castillo v. Richmond, G.R. No. L-21127, Feb. 9, 1924.* <https://lawphil.net/judjuris/juri1924/feb1924/gr_21127_1924.html>

[^q4-rivera-interest]: **Rivera v. Solidbank Corp.** — "Thus, in determining whether the contract is reasonable or not, the trial court should consider the following factors: (a) whether the covenant protects a legitimate business interest of the employer; (b) whether the covenant creates an undue burden on the employee; (c) whether the covenant is injurious to the public welfare; (d) whether the time and territorial limitations contained in the covenant are reasonable; and (e) whether the restraint is reasonable from the standpoint of public policy." *Rivera v. Solidbank Corp., G.R. No. 163269, Apr. 19, 2006.* <https://lawphil.net/judjuris/juri2006/apr2006/gr_163269_2006.html>

[^q4-tiu-trade]: **Tiu v. Platinum Plans Phil., Inc.** — "It is also limited as to trade, since it only prohibits petitioner from engaging in any pre-need business akin to respondent's." *Tiu v. Platinum Plans Phil., Inc., G.R. No. 163512, Feb. 28, 2007.* <https://lawphil.net/judjuris/juri2007/feb2007/gr_163512_2007.html>

[^q5-ferrazzini-void]: **Ferrazzini v. Gsell** — "The contract under consideration, tested by the law, rules and principles above set forth, is clearly one in undue or unreasonable restraint of trade and therefore against public policy. It is limited as to time and space but not as to trade." *Ferrazzini v. Gsell, G.R. No. L-10712, Aug. 10, 1916.* <https://lawphil.net/judjuris/juri1916/aug1916/gr_l-10712_1916.html>

[^q5-tiu-goodfaith]: **Tiu v. Platinum Plans Phil., Inc.** — "Not being contrary to public policy, the non-involvement clause, which petitioner and respondent freely agreed upon, has the force of law between them, and thus, should be complied with in good faith." *Tiu v. Platinum Plans Phil., Inc., G.R. No. 163512, Feb. 28, 2007.* <https://lawphil.net/judjuris/juri2007/feb2007/gr_163512_2007.html>

[^daichi-civil]: **Dai-Chi Electronics Mfg. Corp. v. Villarama** — "Such cause of action is within the realm of Civil Law, and jurisdiction over the controversy belongs to the regular courts. More so when we consider that the stipulation refers to the post-employment relations of the parties." *Dai-Chi Electronics Mfg. Corp. v. Villarama, G.R. No. 112940, Nov. 21, 1994.* <https://lawphil.net/judjuris/juri1994/nov1994/gr_112940_1994.html>

[^portillo-civil]: **Portillo v. Rudolf Lietz, Inc.** — "In accordance with jurisprudence, breach of the undertaking is a civil law dispute, not a labor law case." *Portillo v. Rudolf Lietz, Inc., G.R. No. 196539, Oct. 10, 2012.* <https://lawphil.net/judjuris/juri2012/oct2012/gr_196539_2012.html>

[^yusen-civil]: **Yusen Air & Sea Service Phils., Inc. v. Villamor** — "It merely seeks to recover damages based on the parties' contract of employment as redress for respondent's breach thereof. Such cause of action is within the realm of Civil Law, and jurisdiction over the controversy belongs to the regular courts." *Yusen Air & Sea Service Phils., Inc. v. Villamor, G.R. No. 154060, Aug. 16, 2005.* <https://lawphil.net/judjuris/juri2005/aug2005/gr_154060_2005.html>

[^portillo-no-setoff]: **Portillo v. Rudolf Lietz, Inc.** — "There is no causal connection between the petitioner employees' claim for unpaid wages and the respondent employers' claim for damages for the alleged ‘Goodwill Clause’ violation." *Portillo v. Rudolf Lietz, Inc., G.R. No. 196539, Oct. 10, 2012.* <https://lawphil.net/judjuris/juri2012/oct2012/gr_196539_2012.html>

[^century-violation]: **Century Properties, Inc. v. Babiano** — "Irrefragably, this is a glaring violation of the ‘Confidentiality of Documents and Non-Compete Clause’ in his employment contract with CPI, thus, justifying the forfeiture of his unpaid commissions." *Century Properties, Inc. v. Babiano, G.R. No. 220978, July 5, 2016.* <https://lawphil.net/judjuris/juri2016/jul2016/gr_220978_2016.html>

[^century-forfeiture]: **Century Properties, Inc. v. Babiano** — "Finally, if undersigned breaches any terms of this contract, forms of compensation including commissions and incentives will be forfeited." *Century Properties, Inc. v. Babiano, G.R. No. 220978, July 5, 2016.* <https://lawphil.net/judjuris/juri2016/jul2016/gr_220978_2016.html>

[^consulta-reasonable]: **Consulta v. Court of Appeals** — "The exclusivity provision was a reasonable restriction designed to prevent similar acts prejudicial to Pamana's business interest." *Consulta v. Court of Appeals, G.R. No. 145443, Mar. 18, 2005.* <https://lawphil.net/judjuris/juri2005/mar2005/gr_145443_2005.html>

[^consulta-status]: **Consulta v. Court of Appeals** — "Consulta was an independent agent and not an employee of Pamana." *Consulta v. Court of Appeals, G.R. No. 145443, Mar. 18, 2005.* <https://lawphil.net/judjuris/juri2005/mar2005/gr_145443_2005.html>

[^ollendorff-injunction]: **Ollendorff v. Abrahamson** — "With respect to the contention that an injunction may only be granted to prevent irreparable injury, the answer is that any continuing breach of a valid negative covenant is irreparable by the ordinary process of courts of law." *Ollendorff v. Abrahamson, G.R. No. 13228, Sept. 13, 1918.* <https://lawphil.net/judjuris/juri1918/sep1918/gr_13228_1918.html>

[^civilcode-1226]: **Civil Code of the Philippines (RA 386), Art. 1226** — "Article 1226. In obligations with a penal clause, the penalty shall substitute the indemnity for damages and the payment of interests in case of noncompliance, if there is no stipulation to the contrary." *Civil Code of the Philippines, Republic Act No. 386, Art. 1226.* <https://lawphil.net/statutes/repacts/ra1949/ra_386_1949.html>

[^yusen-moot]: **Yusen Air & Sea Service Phils., Inc. v. Villamor** — "Necessarily, upon the expiration of said period, a suit seeking the issuance of a writ of injunction becomes functus oficio and therefore moot." *Yusen Air & Sea Service Phils., Inc. v. Villamor, G.R. No. 154060, Aug. 16, 2005.* <https://lawphil.net/judjuris/juri2005/aug2005/gr_154060_2005.html>

[^mejila-garden-leave]: **Mejila v. Wrigley Philippines, Inc.** — "There is no prohibition under our labor laws against a garden leave clause in an employment contract." *Mejila v. Wrigley Philippines, Inc., G.R. Nos. 199469 & 199505, Sept. 11, 2019.* <https://lawphil.net/judjuris/juri2019/sep2019/gr_199469_2019.html>

[^q11-rivera-certainty]: **Rivera v. Solidbank Corp.** — "A provision on territorial limitation is necessary to guide an employee of what constitutes as violation of a restrictive covenant and whether the geographic scope is co-extensive with that in which the employer is doing business." *Rivera v. Solidbank Corp., G.R. No. 163269, Apr. 19, 2006.* <https://lawphil.net/judjuris/juri2006/apr2006/gr_163269_2006.html>

[^consti-art12]: **1987 Constitution, Article XII, Section 19** — "No combinations in restraint of trade or unfair competition shall be allowed." *1987 Constitution, Art. XII, Sec. 19.* <https://lawphil.net/consti/cons1987.html>