Case Digest (G.R. No. L-12880) Core Legal Reasoning Model
Facts:
This case involves the Filipino Society of Composers and Publishers (FILSCAP), an organization representing copyright owners in the Philippines, and Wolfpac Communications, Inc. (Wolfpac), a company marketing and distributing mobile phone applications including musical works converted into downloadable ringtones. In 2004, FILSCAP discovered that Wolfpac’s website allowed prospective consumers to listen to 20-second samples of songs—part of FILSCAP’s repertoire—via a "pre-listening function" before downloading the ringback tones. FILSCAP demanded that Wolfpac secure licenses and pay royalties for these uses, but Wolfpac refused, arguing this pre-listening was not a public performance and fell outside the scope of the licenses granted by composers. FILSCAP filed a complaint for copyright infringement and damages against Wolfpac. The Regional Trial Court (RTC) of Quezon City ruled that while Wolfpac’s transmission of ringtones constituted communication to the public, the
Case Digest (G.R. No. L-12880) Expanded Legal Reasoning Model
Facts:
- Parties and Background
- FILSCAP (Filipino Society of Composers and Publishers) is an association of copyright owners authorized to grant licenses for public performance, mechanical reproduction, or synchronization of their musical works and to collect royalties.
- Wolfpac Communications, Inc. markets mobile phone applications including ringtones distributed via partner-operators through wireless technology.
- Dispute Origin
- In 2004, FILSCAP found that Wolfpac’s website offered a "pre-listening function" allowing consumers to listen to 20-second samples of songs before downloading ringback tones.
- FILSCAP demanded Wolfpac secure licenses and pay royalties, which Wolfpac refused, claiming no public performance occurred.
- Trial Court Proceedings
- FILSCAP filed a complaint for copyright infringement and damages.
- Wolfpac argued the pre-listening samples: (a) are free, (b) intended for private performance, (c) lack commercial value, and (d) were authorized via agreements with composers.
- The Regional Trial Court held the downloading constituted communication to the public but the pre-listening function did not amount to public performance and was protected under fair use.
- Parties' Positions on Appeal
- FILSCAP contended the pre-listening constituted public performance needing licenses and that fair use was inapplicable.
- Wolfpac argued the sample listening was communication to the public, not public performance, was authorized by agreements, and qualified for fair use.
- Supreme Court Admission and Jurisdiction
- The Supreme Court accepted the petition upon pure questions of law involving copyright exceptions and economic rights distinctions.
Issues:
- Whether the pre-listening ringtones sample on Wolfpac's website constitutes public performance or communication to the public.
- Whether Wolfpac’s use of the samples constitutes copyright infringement.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)