Case Digest (G.R. No. 109993) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In FILIPINO SOCIETY OF COMPOSERS, AUTHORS AND PUBLISHERS, INC. v. TAN, the plaintiff-appellant, a non-profit association duly organized and registered under Philippine law, owned the copyrights to musical compositions including “Dahil Sa Iyo,” “Sapagkat Ikaw Ay Akin,” “Sapagkat Kami Ay Tao Lamang,” and “The Nearness Of You.” On November 7, 1967, it filed Civil Case No. 71222 in the Court of First Instance of Manila against Benjamin Tan, operator of “Alex Soda Fountain and Restaurant,” for infringement of copyright under Act No. 3134 (the Copyright Law). Tan’s combo of professional singers and musicians performed those compositions in his establishment to entertain patrons, who paid only for food and beverages. Appellant demanded a license fee, which Tan refused. The trial court dismissed the complaint, holding that such performances did not fall within the exclusive rights of the copyright owner. The Court of Appeals, deeming the issues purely legal, certified the case to the Su Case Digest (G.R. No. 109993) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Plaintiff-Appellant: Filipino Society of Composers, Authors and Publishers, Inc. (FSCP)
- Defendant-Appellee: Benjamin Tan
- Procedural History
- FSCP demanded payment of license fees; demand ignored.
- FSCP filed complaint for copyright infringement on November 7, 1967 in CFI Manila (Civil Case No. 71222).
- Defendant moved to dismiss for failure to state a cause of action, alleging mere playing/singing not infringing under Sec. 3 of Act 3134.
- CFI dismissed complaint. FSCP appealed to CA (CA-GR No. 46373-R); CA certified pure question of law to the Supreme Court.
Issues:
- Do the playing and singing of FSCP’s copyrighted musical compositions in the restaurant constitute “public performances for profit” under the Copyright Law (Act 3134)?
- If so, can the restaurant operator be held liable for infringement?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)