G.R. No. 205972 - Caterpillar, Inc. vs. Samson

Caterpillar, Inc. (Petitioner) is a foreign corporation manufacturing and distributing footwear, clothing, and related products, known for six core trademarks including "CATERPILLAR," "CAT," "CATERPILLAR & DESIGN," "CAT AND DESIGN," "WALKING MACHINES," and "TRACK-TYPE TRACTOR & DESIGN," all claimed as internationally known marks.
Manolo P. Samson (Respondent) operates retail outlets under the names Itti Shoes Corporation, Kolm's Manufacturing Corporation, and Caterpillar Boutique and General Merchandise, selling footwear and related items under the trademark "CATERPILLAR," registered in 1997 under Trademark Registration No. 64705 by the Intellectual Property Office (IPO).

For unfair competition, Caterpillar filed multiple criminal complaints against Samson.

On July 26, 2000, the Regional Trial Court (RTC) Makati issued search warrants for Samson’s establishments leading to the seizure of products bearing Caterpillar’s Core Marks.
Criminal complaints (I.S. Nos. 2000-1354 to 2000-1364) were filed in the Department of Justice (DOJ).
A civil suit (Civil Case No. Q-00-41446) for unfair competition, damages, and cancellation of trademark was concurrently filed in RTC Quezon City in July 2000; the application for Temporary Restraining Order was denied in August 2000.

On November 15, 2001, DOJ recommended criminal charges for unfair competition under Section 168.3(a) and related provisions of the Intellectual Property Code (IP Code).
Further search warrants were issued in 2000 and 2001, resulting in seizures; twenty-six criminal complaints were filed in January 2001 (I.S. Nos. 2001-42 to 2001-67).
DOJ’s joint resolution in September 2001 also recommended charges under similar provisions.

Samson filed petitions for review with the Secretary of Justice in 2002 against DOJ resolutions.
Samson petitioned the RTC to suspend arraignment in criminal cases citing prejudicial questions related to the pending civil case. The RTC granted the suspension on September 23, 2002, in Criminal Cases Nos. 02-238 to 02-243.
Caterpillar challenged the suspension before the Court of Appeals (CA) by a petition for certiorari in 2003 (CA-G.R. SP No. 75526).
Meanwhile, the RTC of Valenzuela quashed the search warrants upon Samson's motion, leading Acting Justice Secretary Ma. Merceditas N. Gutierrez to order withdrawal of the related criminal informations in January 2003; subsequent CA decisions reinstated the cases.

In August 2002, new search warrants were issued against Samson’s outlets following continued distribution of allegedly infringing goods.
Caterpillar filed additional criminal complaints in the DOJ (I.S. Nos. 2002-995 to 2002-1036).
DOJ dismissed the complaints in August 2003 due to lack of probable cause, affirmed by the Secretary of Justice in 2005 and 2007.
Caterpillar filed a petition for review with the CA (CA-G.R. SP No. 102316) which was denied in 2012 and the motion for reconsideration denied in 2013, prompting appeal to the Supreme Court.

Whether the Court of Appeals erred in dismissing Caterpillar’s petition for certiorari.
Whether the RTC's order suspending criminal proceedings on grounds of a prejudicial question (civil case on trademark ownership pending) was proper or contrary to law.
Whether criminal complaints for unfair competition can proceed independently and simultaneously with the civil case for the same matters.

Whether the Court of Appeals erred in dismissing Caterpillar's petition for review on the ground of improper remedy despite evidence of grave abuse of discretion by the Secretary of Justice in ruling there was no probable cause to charge Samson with unfair competition.
Whether Caterpillar should be allowed liberal interpretation of procedural rules to pursue the matter on the merits.

Whether the suspension of criminal proceedings on the basis of a prejudicial question was justified.
Whether the DOJ and Secretary of Justice correctly determined the absence of probable cause to indict Samson for unfair competition.