Case Digest (G.R. No. 205972)
Facts:
Caterpillar, Inc. v. Manolo P. Samson, G.R. Nos. 205972 and 164352, November 09, 2016, the Supreme Court First Division, Bersamin, J., writing for the Court.Caterpillar, Inc. (petitioner) is an international manufacturer claiming six core trademarks (the Core Marks). Manolo P. Samson (respondent), doing business under various names including Caterpillar Boutique, possessed a local Trademark Registration No. 64705 (1997) for "CATERPILLAR" and operated retail outlets in the Philippines. Alleging unfair competition, Caterpillar pursued both criminal complaints before the Department of Justice (DOJ) and a civil suit for unfair competition, damages and cancellation of trademark (Civil Case No. Q-00-41446) in the RTC, Quezon City.
Beginning in July 2000, the NBI executed multiple search warrants at Samson’s establishments and seized goods bearing the Core Marks. Caterpillar filed a series of criminal complaints in the DOJ (I.S. Nos. 2000-1354 to 1364; 2001-42 to 2001-67; later 2002 complaints) and concurrently filed the civil action seeking cancellation of Samson’s trademark and injunctive relief; the RTC denied Caterpillar’s TRO application. The DOJ’s investigating prosecutors issued joint resolutions at various times recommending charges; some were later reversed or set aside on procedural grounds (including quashed warrants), and some were dismissed for lack of probable cause.
In Muntinlupa RTC Criminal Cases Nos. 02-238 to 02-243, Presiding Judge Lerma granted Samson’s motion to suspend arraignment and other criminal proceedings on the ground that Civil Case No. Q-00-41446 presented a prejudicial question; the suspension prompted Caterpillar to file certiorari in the Court of Appeals (CA) (C.A.-G.R. SP No. 75526). The CA dismissed Caterpillar’s certiorari petition, finding no grave abuse in the RTC’s suspension; Caterpillar elevated that dismissal to the Supreme Court as G.R. No. 164352.
Separately, following the August 2002 RIID-NCRPO searches and seizures at multiple Samson outlets, Caterpillar filed additional DOJ complaints (I.S. Nos. 2002-995 to 1036). State Prosecutor Melvin J. Abad issued a joint resolution (Aug. 21, 2003) finding no probable cause; the Secretary of Justice affirmed the dismissal (Sept. 19, 2005) and denied reconsideration (Dec. 20, 2007). Caterpillar sought review in the CA under Rule 43 (C.A.-G.R. SP No. 102316); the CA denied due course and dismissed the petition, holding Rule 43 was the wrong remedy and that certiorari did not sufficiently show grave abuse. Caterpillar brought the matter to the Supreme Court as G.R. No. 205972.
The consolidated petitions therefore presented (1) the propriety of the RTC’s suspension of crimin...(Subscriber-Only)
Issues:
- Did the Court of Appeals commit reversible error in upholding the suspension of arraignment and other proceedings in the criminal cases on the ground that Civil Case No. Q-00-41446 presented a prejudicial question?
- Did the Court of Appeals err in denying Caterpillar’s challenge to the Secretary of Justice’s resolution finding no probable cause, including by treating the petition under the wrong procedural rule (Rule 43 instead of Rule 65) and by failing to find grave abuse of d...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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