Case Digest (G.R. No. 233918) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In FILIPINO SOCIETY OF COMPOSERS, AUTHORS AND PUBLISHERS, INC. v. ANREY, INC. (G.R. No. 233918, August 9, 2022), petitioner FILSCAP, a nonprofit Caribbean Management Organization accredited by the Intellectual Property Office, alleged that respondent Anrey, Inc., operator of three Sizzling Plate restaurants in Baguio City (Session Road, Abanao Extension, SM Baguio Luneta Hill), publicly performed copyrighted music without licenses. Between July and September 2008, FILSCAP’s representative monitored the establishments and recorded 12 songs from its repertoire over multiple visits. FILSCAP sent six letters demanding licenses and payment of fees amounting to P6,300 per restaurant, but Anrey refused, contending its radio stations had paid royalties and that any broadcast was for its staff and not a public performance. FILSCAP then filed an amended complaint for copyright infringement in the RTC of Baguio City seeking compensatory, nominal, exemplary damages, and attorney’s fees. The... Case Digest (G.R. No. 233918) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- FILSCAP’s Role and Agreements
- FILSCAP is a non-profit collective management organization accredited by IPOPHL and CISAC.
- Members (composers, authors, publishers) assign FILSCAP exclusive public-performance and communication-to-the-public rights over their musical works.
- Reciprocal agreements authorize FILSCAP to license public performances in the Philippines of foreign repertoire.
- Anrey’s Restaurants and Monitoring
- Anrey, Inc. operates three Sizzling Plate restaurants in Baguio City:
- #116 Session Road
- #134 Abanao Extension
- SM Baguio branch
- FILSCAP’s representative monitored them on four dates in July–September 2008, documenting public radio broadcasts of FILSCAP-managed songs.
- FILSCAP sent six demand letters (July 2008–March 2009) to secure licenses and royalties; Anrey did not respond.
- Court Proceedings
- FILSCAP sued in RTC for infringement, claiming P18,900 in compensatory damages, P300,000 nominal, P100,000 exemplary, and P50,000 attorneys’ fees.
- RTC (April 2015) dismissed under Sec. 184(i) (charitable/educational exemption).
- CA (April 2017) affirmed, applying U.S. “homestyle/business” exemptions for small establishments.
Issues:
- Whether playing unlicensed radio broadcasts as background music in Anrey’s public dining areas constitutes infringement of FILSCAP’s exclusive rights to public performance and/or communication to the public under Sec. 177 of RA 8293.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)