Title
Del Rosario vs. Court of Appeals
Case
G.R. No. 115106
Decision Date
Mar 15, 1996
The Supreme Court issues a preliminary injunction in favor of Del Rosario, halting Janito Corporation's production of a similar sing-along system deemed infringing on his patent.
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Case Digest (G.R. No. 115106)

Facts:

  • Roberto L. Del Rosario filed a patent infringement complaint against Janito Corporation on January 18, 1993, in the Regional Trial Court of Makati.
  • Del Rosario claimed to be the patentee of a karaoke system under two utility model patents: UM-5269 (issued June 2, 1983) and UM-6237 (issued November 14, 1986).
  • Both patents were initially effective for five years and were extended for another five years.
  • Del Rosario's invention included an amplifier, tape mechanisms, a tuner, and a microphone mixer to enhance vocal performance.
  • In early 1990, Del Rosario discovered Janito Corporation was producing a similar karaoke system branded as "Miyata."
  • Del Rosario sought a writ of preliminary injunction to prevent Janito from using, selling, or advertising their karaoke system.
  • The trial court issued a temporary restraining order on February 5, 1993, followed by a writ of preliminary injunction on February 24, 1993.
  • Janito Corporation contested the trial court's order by filing a petition for certiorari with the Court of Appeals.
  • On November 15, 1993, the Court of Appeals set aside the trial court's order, concluding there was no patent infringement.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed the Court of Appeals' decision dated November 15, 1993.
  • The order of the trial court dated February 24, 1993, granting Del Rosario the writ of preliminary injunction was reinsta...(Unlock)

Ratio:

  • The Supreme Court stated that a writ of preliminary injunction is a preservative remedy to protect substantive rights and is not a standalone cause of action.
  • The trial court established that Del Rosario held valid utility model patents and that Janito's karaoke system was substantially similar to Del Rosario's invention.
  • The burden of proof shifted to Janito to prove that Del Rosar...continue reading

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