Title
Aguas vs. De Leon
Case
G.R. No. L-32160
Decision Date
Jan 30, 1982
De Leon's patent for tile-making improvements upheld; Aguas found to infringe by using identical moulds, damages awarded but moral damages reduced.
A

Case 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)

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