Facts:

The case involves Roberto L. Del Rosario as the petitioner and the Court of Appeals and Janito Corporation as the respondents. The events leading to the case began on January 18, 1993, when Del Rosario filed a complaint for patent infringement against Janito Corporation in the Regional Trial Court of Makati. Del Rosario claimed to be the patentee of an audio equipment known as the sing-along system or karaoke, under Letters Patent No. UM-5269 issued on June 2, 1983, and Letters Patent No. UM-6237 issued on November 14, 1986. Both patents were effective for five years and were extended for another five years starting June 2, 1988, and November 14, 1991, respectively. Del Rosario described his invention as a compact machine that includes an amplifier, tape mechanisms, a tuner, and a microphone mixer, designed to enhance the user's voice.

In early 1990, Del Rosario discovered that Janito Corporation was manufacturing a similar sing-along system branded as "Miyata"...

Facts:

Background of the Case

• Roberto L. del Rosario, the petitioner, filed a complaint for patent infringement against Janito Corporation, the private respondent, on 18 January 1993.
• Del Rosario claimed to be the patentee of an audio equipment and improved audio equipment, commonly known as the sing-along system or karaoke, under Letters Patent No. UM-5269 (dated 2 June 1983) and Letters Patent No. UM-6237 (dated 14 November 1986).
• Both patents were initially valid for five years and were extended for another five years starting 2 June 1988 and 14 November 1991, respectively.

Description of the Patented Invention

• Del Rosario described his sing-along system as a compact machine incorporating an amplifier speaker, tape mechanisms, optional tuner or radio, and a microphone mixer with features like echo or reverb to enhance the user's voice.

Alleged Infringement

• In early 1990, del Rosario discovered that Janito Corporation was manufacturing a sing-along system under the trademark "Miyata" or "Miyata Karaoke," which he claimed was substantially similar to his patented system.
• Del Rosario sought a writ of preliminary injunction from the trial court to stop Janito Corporation from manufacturing, selling, and advertising the Miyata system.

Trial Court's Decision

• On 5 February 1993, the trial court issued a temporary restraining order against Janito Corporation.
• On 24 February 1993, the trial court granted a writ of preliminary injunction, finding that del Rosario was the holder of a utility model patent and that Janito Corporation's Miyata system was substantially similar to del Rosario's patented model.

Appeal to the Court of Appeals

• Janito Corporation challenged the trial court's order through a petition for certiorari before the Court of Appeals.
• On 15 November 1993, the Court of Appeals set aside the trial court's order, ruling that there was no patent infringement because the karaoke system was a universal product manufactured worldwide before del Rosario's patents were issued.

Petition to the Supreme Court

• Del Rosario filed a petition for review with the Supreme Court, arguing that the Court of Appeals erred in its decision and that the trial court's findings should be respected.

Issue:

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Ruling:

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Ratio:

1. Patent Infringement: A patent is infringed when the essential or substantial features of the patented invention are appropriated, or when the alleged infringing device is substantially identical to the patented invention in function, result, and mode of operation.
2. Prima Facie Evidence of Infringement: Del Rosario presented sufficient evidence to show that Janito Corporation's Miyata system was substantially similar to his patented models, particularly Utility Model No. 6237, which improved on his earlier model.
3. Presumption of Patent Validity: The Director of Patents' decision to grant a patent is presumed correct, and the burden of proving invalidity lies on the party challenging the patent. Janito Corporation failed to present competent evidence to overcome this presumption.
4. Purpose of Preliminary Injunction: A preliminary injunction is a provisional remedy to protect the rights of a patentee during the pendency of litigation. Del Rosario demonstrated a clear legal right to be protected, and the injunction was necessary to prevent irreparable injury.