Case Digest (G.R. No. 131522) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Pacita I. Habana, Alicia L. Cinco and Jovita N. Fernando v. Felicidad C. Robles and Goodwill Trading Co., Inc. (G.R. No. 131522, July 19, 1999), petitioners are the co-authors and registered copyright owners of College English for Today (CET), Books 1 and 2, and Workbook for College Freshman English, Series 1. In 1985, respondents Felicidad C. Robles (author/publisher) and Goodwill Trading Co., Inc. (publisher/distributor) released Developing English Proficiency (DEP), Books 1 and 2, also covered by copyright. While surveying the market to revise their texts, petitioners discovered that significant passages, illustrative examples and the overall scheme of DEP closely mirrored those in CET without authorization or attribution. After demands to cease and desist and to recall DEP went unanswered, petitioners filed on July 7, 1988 a complaint for infringement and/or unfair competition with damages before the Regional Trial Court of Makati, Branch 36. Respondents denied copying, c Case Digest (G.R. No. 131522) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Works
- Petitioners
- Pacita I. Habana, Alicia L. Cinco, and Jovita N. Fernando – authors and co-owners of copyrights covering:
- College English for Today (CET), Books 1 and 2
- Workbook for College Freshman English, Series 1
- Respondents
- Felicidad C. Robles – author/publisher of Developing English Proficiency (DEP), Books 1 and 2 (1985 edition)
- Goodwill Trading Co., Inc. – publisher/distributor and co-owner of DEP’s copyright
- Allegations and Procedural History
- Discovery of Similarities
- Petitioners, while revising CET, found DEP “strikingly similar” in contents, presentation, illustrations and examples
- Itemized comparison showed identical or substantially similar pages and examples
- Pre-litigation Demands
- Petitioners demanded that respondents cease distribution of DEP and pay damages for alleged plagiarism and infringement
- Respondents ignored demands
- Trial Court Proceedings
- July 7, 1988 – petitioners filed complaint for “Infringement and/or Unfair Competition with Damages” before RTC Makati, Branch 36
- Respondent Robles filed bill of particulars; Goodwill filed answer denying privity and liability; Robles denied copying and asserted independent research, common syllabus and fair use
- Parties stipulated to resolve infringement issue first
- April 23, 1993 – RTC dismissed complaint, held no infringement, and awarded attorney’s fees of ₱20,000 to Robles and ₱5,000 to Goodwill
- Petitioners appealed to the Court of Appeals (CA G.R. CV No. 44053)
- Court of Appeals and Supreme Court
- June 27, 1997 – Court of Appeals affirmed dismissal, deleted attorney’s fees award
- November 25, 1997 – CA denied petitioners’ motion for reconsideration
- Petitioners filed Rule 45 petition for review on certiorari before the Supreme Court
Issues:
- Copyright Infringement
- Whether DEP’s textual, thematic and sequential similarity to CET constitutes infringement under P.D. 49 and/or RA 8293
- Animus Furandi
- Whether respondents’ refusal to withdraw DEP from the market after notice evidences wrongful intent to infringe
- Fair Use Exception
- Whether respondent Robles abused the right to fair use under Section 11 of P.D. 49 by copying petitioners’ work without acknowledgment
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)