Case Digest (G.R. No. L-31335)
Facts:
In Domiciano A. Aguas v. Conrado G. de Leon, G.R. No. L-32160, decided January 30, 1982 under the 1973 Constitution, Conrado G. de Leon filed on April 14, 1962 in the CFI of Rizal at Quezon City a complaint for infringement of Philippine Patent No. 658, covering “a new and useful improvement in the process of making mosaic pre-cast tiles.” He sought a preliminary injunction and damages alleging that Domiciano A. Aguas manufactured and sold tiles embodying his patented process, and that F.H. Aquino & Sons supplied Aguas with the moulds for production. The trial court granted the injunction, declared the patent valid and infringed, and ordered perpetual injunctive relief, delivery of infringing moulds and tiles, plus actual damages (₱10,020.99), moral damages (₱50,000), exemplary damages (₱5,000), attorney’s fees (₱5,000) and costs. Aguas appealed to the Court of Appeals, which on August 5, 1969 affirmed the judgment but reduced moral damages to ₱3,000. Aguas then sought certiorarCase Digest (G.R. No. L-31335)
Facts:
- Background and Patent Application
- Conrado G. de Leon, claiming to be the original inventor of certain improvements in the process of making mosaic pre-cast tiles, filed Philippine Patent Application No. 658 on December 1, 1959.
- The Philippine Patent Office granted Letters Patent No. 658 on May 5, 1960, covering “a new and useful improvement in the process of making mosaic pre-cast tiles.”
- De Leon marked and sold tiles embodying his patented process, obtained an exclusive license, and asked purchasers to respect his rights.
- Infringement and Lower Court Proceedings
- On April 14, 1962, de Leon sued Domiciano A. Aguas and F.H. Aquino & Sons in the CFI of Rizal (Quezon City) for patent infringement, seeking injunctive relief and damages (actual, moral, exemplary, attorney’s fees).
- The trial court granted a preliminary injunction the same day, restraining the defendants from making or selling tiles embodying the patented process.
- F.H. Aquino & Sons had originally engraved molds for de Leon, then later engraved identical molds for Aguas; Aguas used these molds to produce and market infringing tiles.
- On December 29, 1965, the trial court found the patent valid and infringed, issued a perpetual injunction, ordered delivery of infringing items, and awarded:
- Actual damages: ₱10,020.99
- Moral damages: ₱50,000.00
- Exemplary damages: ₱5,000.00
- Attorney’s fees: ₱5,000.00
- Costs of suit
- Appeals and Petition for Certiorari
- Domiciano Aguas appealed to the Court of Appeals, challenging patent validity and infringement findings, and seeking cancellation of the patent and dismissal of the complaint.
- On August 5, 1969, the Court of Appeals affirmed the trial court in all respects, except that it reduced moral damages from ₱50,000 to ₱3,000.
- Aguas then filed a petition for certiorari with the Supreme Court, contending that the CA erred in upholding the patent’s validity and in the assessment of damages.
Issues:
- Was Letters Patent No. 658 valid and patentable as an improvement of the old process of making mosaic pre-cast tiles?
- Did Domiciano A. Aguas infringe the patent by having identical molds engraved and manufacturing tiles embodying the patented process?
- What is the appropriate measure of damages—actual, moral, exemplary, and attorney’s fees—to which the patentee is entitled?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)