Case Digest (G.R. No. 110318)
Facts:
Columbia Pictures, Inc., et al. v. Court of Appeals, Sunshine Home Video, Inc. and Danilo A. Pelindario, G.R. No. 110318, August 28, 1996, Supreme Court En Banc, Regalado, J., writing for the Court. Petitioners are several foreign film companies (collectively, petitioners); respondents are the Court of Appeals (respondent court), Sunshine Home Video, Inc. and its proprietor Danilo A. Pelindario (private respondents).The factual background begins with petitions by petitioners to the National Bureau of Investigation (NBI) complaining of alleged video piracy in Metro Manila. On November 14, 1987, NBI Senior Agent Lauro C. Reyes applied for Search Warrant No. 87-053 against Sunshine seeking seizure of, inter alia, allegedly pirated videocassettes and equipment; affidavits and depositions of Agent Reyes, Rene C. Baltazar (a private researcher), and Atty. Rico V. Domingo (attorney‑in‑fact for petitioners) were taken. The trial court issued the search warrant; it was served and executed on December 14, 1987, with various tapes and paraphernalia seized and a Return filed December 16, 1987.
Private respondents moved to lift/quash the warrant; an initial motion was denied by the trial court (order of September 5, 1988), but upon reconsideration the trial court reversed itself and on November 22, 1988 quashed Search Warrant No. 87-053, relying on the then‑recent pronouncement in 20th Century Fox Film Corporation v. Court of Appeals that the master tape must be presented to establish the necessary linkage for probable cause in videogram infringement cases. Petitioners appealed the trial court’s quashal to the Court of Appeals, which on July 22, 1992 affirmed the trial court’s quashal and denied petitioners’ motion for reconsideration on May 10, 1993. Petitioners then filed a peti...(Pro-only)
Issues:
- Do the foreign film corporations petitioners have legal capacity to sue in Philippine courts notwithstanding that they are unlicensed to do business in the Philippines?
- Was the trial court’s quashal of Search Warrant No. 87-053, affirmed by the Court of Appeals through retroactive application of the master‑tape rule in 20th Ce...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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