Case Digest (G.R. No. L-32160)
Facts:
Domiciano A. Aguas v. Conrado G. De Leon and Court of Appeals, G.R. No. L-32160, January 30, 1982, Supreme Court First Division, Fernandez, J., writing for the Court.On April 14, 1962, Conrado G. De Leon filed in the Court of First Instance of Rizal at Quezon City a complaint for infringement of patent (Letters Patent No. 658) against Domiciano A. Aguas and F.H. Aquino & Sons, alleging that he was the inventor of a “new and useful improvement in the process of making mosaic pre-cast tiles,” that Patent No. 658 had been lawfully granted to him, and that the defendants were making, using and selling tiles and moulds that infringed his patent; he sought injunctive relief, damages (actual, moral, exemplary), and attorney’s fees. A writ of preliminary injunction issued the same day.
Aguas answered on May 23, 1962, denying inventorship and asserting that the claimed process was not new or inventive because it had been used previously in the Philippines and abroad; he also asserted differences in composition and design and noted that third parties held certain design patents. Trial proceeded; F.H. Aquino & Sons had engraved moulds for both parties and was alleged to have produced moulds for Aguas similar to De Leon’s.
The Court of First Instance rendered judgment on December 29, 1965 declaring Patent No. 658 valid and infringed, granting a perpetual injunction, ordering delivery of infringing items, and awarding damages: actual P10,020.99, moral P50,000, exemplary P5,000, attorney’s fees P5,000, plus costs. F.H. Aquino & Sons did not appeal; Aguas alone appealed to the Court of Appeals.
On August 5, 1969 the Court of Appeals (decision authored by Justice Jose M. Mendoza, concurred in by Justices Lucero and Perez) affirmed the trial court’s judgment but reduced moral damages to P3,000.00. The Court of Appeals found that De Leon introduced an inventive improvement — critical depth, lip width, easement, composition and the ability to produce thin (1/8") yet durable sculptured tiles — and that Aguas had actual knowledge and used moulds embodying those features.
Petitioner Aguas sought review by the Supreme Court via petition for certiorari to this Court to challenge the Court of Appeals’ affirmance, contending chiefly that the patent was ...(Pro-only)
Issues:
- May the Supreme Court overturn the Court of Appeals’ factual findings in this patent and infringement case?
- Was Letters Patent No. 658 a valid patent — i.e., did it claim a patentable improvement that was new, useful and inventive under the patent law?
- Did petitioner Domiciano A. Aguas infringe Patent No. 658?
- Were the awards of actual, moral, exemplary damages and attorney’s ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)