Case Digest (G.R. No. 115106)
Facts:
In Roberto L. del Rosario v. Court of Appeals and Janito Corporation, petitioner Roberto L. del Rosario, holder of Letters Patent No. UM-5269 dated June 2, 1983 and No. UM-6237 dated November 14, 1986 (each for a term of five years, extended for another five years), filed on January 18, 1993 before the Regional Trial Court of Makati, Branch 57, a complaint for patent infringement against private respondent Janito Corporation. Del Rosario’s utility models covered a “sing-along system” or karaoke, described as a compact machine integrating an amplifier-speaker, tape mechanisms, tuner, echo/reverb effects and microphone mixer within a single cabinet. He alleged that in early 1990 Janito manufactured and sold under the trademark MIYATA a device substantially identical to his patented models. On February 5, 1993, the trial court issued a temporary restraining order; on February 24, 1993 it granted a writ of preliminary injunction enjoining Janito from using, manufacturing, selling orCase Digest (G.R. No. 115106)
Facts:
- Background and Patent Details
- On 18 January 1993, petitioner Roberto L. del Rosario filed a complaint for patent infringement against Janito Corporation before the Regional Trial Court (RTC) of Makati, Branch 57.
- Petitioner held two utility model patents issued by the Director of Patents:
- Letters Patent No. UM-5269 (2 June 1983), extended for five years from 2 June 1988.
- Letters Patent No. UM-6237 (14 November 1986), extended for five years from 14 November 1991.
- Description of the Patented Sing-Along System
- Both utility models featured a multi-purpose compact machine with:
- A cubical casing with a vertical partition dividing rear and front compartments.
- A transistorized amplifier circuit with echo/reverb section mounted on printed circuit boards.
- Front-compartment loudspeaker baffle, a tape player/recorder, microphone mixer and control panel.
- The second patent (UM-6237) added a removable control panel fitted with recorder/player and a detachable second cubical casing with tape racks and speaker.
- Trial Court Proceedings
- Early 1990: Petitioner learned Janito manufactured a “Miyata karaoke” system allegedly substantially similar to his patents.
- 5 February 1993: RTC issued a Temporary Restraining Order enjoining Janito from manufacturing, using, selling or advertising the Miyata system.
- 24 February 1993: RTC granted a Writ of Preliminary Injunction upon bond, finding a prima facie case of patent infringement.
- Court of Appeals Proceedings
- Janito petitioned the Court of Appeals (CA) via certiorari to annul the PI order.
- 15 November 1993: CA granted the petition, set aside the RTC’s injunction, and denied the motion for reconsideration.
- CA held that Karaoke systems were universal products pre-dating the petitioner’s patents and thus no infringement.
- Petition for Review to the Supreme Court
- Petitioner invoked errors of the CA including factual determination in certiorari, taking judicial notice of self-serving facts, and disregard of RTC’s findings.
- Petitioner maintained that he satisfied requirements for injunctive relief: clear legal right (valid patents) and probable infringement.
Issues:
- Whether the Court of Appeals erred in considering and resolving factual issues in a certiorari proceeding.
- Whether the CA improperly took judicial notice of respondents’ self-serving factual assertions.
- Whether the CA disregarded and substituted its findings for those of the trial court without jurisdiction or due process.
- Whether there was any basis for the CA to grant a writ of preliminary injunction in favor of Janito Corporation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)