Case Digest (G.R. No. 257446) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In COSAC, Inc. v. Filipino Society of Composers, Authors and Publishers, Inc., FILSCAP is a non-stock, non-profit corporation empowered by deeds of assignment from local composers and reciprocal representation agreements with foreign societies to license and collect royalties for the public performance of copyrighted musical works. On February 3, 2005 and January 13, 2006, FILSCAP representatives monitoring Off the Grill Bar and Restaurant in Quezon City, owned and operated by COSAC, Inc., discovered live bands performing and sound recordings playing without a FILSCAP license or payment of royalties. FILSCAP sent demand letters on September 20, 2004, October 14, 2004, and a final demand on November 10, 2005, all ignored by COSAC. Consequently, FILSCAP filed a Complaint for copyright infringement on February 13, 2006. FILSCAP presented deeds of assignment, reciprocal representation agreements, certifications of membership in the International Confederation of Societies of Authors Case Digest (G.R. No. 257446) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Representation
- Petitioner: COSAC, Inc., owner‐operator of Off the Grill Bar and Restaurant in Quezon City.
- Respondent: Filipino Society of Composers, Authors and Publishers, Inc. (FILSCAP), a non-stock, non-profit collective management organization authorized to license and enforce public performance rights of musical works.
- Events Leading to Litigation
- Monitoring (Feb. 3, 2005 & Jan. 13, 2006): FILSCAP agents observed Off the Grill playing live and recorded music from its repertoire without a license.
- Demand Letters: FILSCAP sent letters (Sept. 20 & Oct. 14, 2004) and a final demand (Nov. 10, 2005) instructing COSAC to secure licenses and pay royalties.
- Filing of Complaint (Feb. 13, 2006): FILSCAP sued COSAC for copyright infringement, unpaid license fees/royalties, damages, attorney’s fees, and litigation expenses.
- COSAC’s Defense and Counterclaim: Denied infringement and assailed FILSCAP’s standing; argued that music becomes public upon broadcast and questioned authority to collect fees.
- Evidence Presented by FILSCAP:
- Deeds of assignment from local authors and reciprocal agreements with foreign societies.
- Certificate of Authentication and ICSAC certification confirming FILSCAP’s status.
- Fiche Internationale database listing assigned works.
- Judicial affidavits of FILSCAP agents cataloguing 25 live-performed and 22 mechanically played songs.
- Fee matrix based on seating capacity to compute royalties.
- Procedural History
- RTC Decision (Oct. 24, 2012): Found infringement; awarded PHP 317,050.00 in unpaid royalties, PHP 5,778.17 for monitoring expenses, interest, PHP 52,003.47 attorney’s fees, and costs.
- RTC Order (July 22, 2013): Denied COSAC’s motions for reconsideration.
- CA Decision (May 28, 2015): Affirmed RTC but deleted monitoring expenses; denied COSAC’s counterclaim.
- CA Resolution (Jan. 14, 2016): Denied reconsideration.
- SC Petition: COSAC appealed via Petition for Review on Certiorari under Rule 45.
Issues:
- Did COSAC infringe FILSCAP’s exclusive public performance rights under the Intellectual Property Code?
- Must COSAC pay unpaid license fees/royalties, damages, and attorney’s fees?
- Is publication in the IPO Gazette required to validate FILSCAP’s deeds of assignment/reciprocal agreements?
- Is FILSCAP a real party‐in‐interest with standing to sue?
- Is COSAC entitled to its counterclaims for attorney’s fees and litigation expenses?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)