Case Digest (G.R. No. 234346) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves L.C. Big Mak Burger, Inc. (hereinafter referred to as the "petitioner") and McDonald's Corporation (the "respondent"). The matter originated from a trademark infringement and unfair competition complaint filed by the respondent against the petitioner in Civil Case No. 90-1507 in the Regional Trial Court (RTC) of Makati City, Branch 137. On August 16, 1990, the RTC issued a preliminary injunction prohibiting the petitioner from using the name "Big Mak" or any similar marks that might confuse the public into believing it is associated with McDonald's. Following trial, the RTC ruled on September 5, 1994, in favor of the respondent, making the injunction permanent, awarding damages, and dismissing counterclaims for lack of merit.After an appeal process that included reversals by both the Court of Appeals (CA) and the Supreme Court, the Supreme Court ultimately reinstated the RTC's decision on August 18, 2004, confirming the petitioner’s liability for tradem
Case Digest (G.R. No. 234346) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Case
- This petition is a review on certiorari under Rule 45, challenging the decisions of the Court of Appeals dated February 2, 2017, and its Resolution dated July 26, 2017.
- The petition arises from a trademark infringement and unfair competition case originally filed by McDonald’s Corporation against L.C. Big Mak Burger, Inc. and its president, Francis Dy, before the RTC of Makati City, Branch 137.
- Infringement and Injunction Proceedings
- The Infringement Case
- Filed in Civil Case No. 90-1507, McDonald’s sought to prohibit L.C. Big Mak Burger, Inc. from using “Big Mak” or any confusingly similar mark.
- On August 16, 1990, the RTC issued a writ of preliminary injunction ordering the petitioner to cease:
- Using “Big Mak” or any mark/colorably imitative of McDonald’s “Big Mac.”
- Trial Court Decision
- On September 5, 1994, the RTC rendered a decision permanently enjoining petitioner from using the disputed mark, and ordered L.C. Big Mak Burger, Inc. to pay actual damages, exemplary damages, and attorney’s fees.
- The decision also dismissed counterclaims and unrelated actions against certain individuals due to lack of merit and insufficient evidence.
- Procedural History
- The CA reversed the RTC decision on November 26, 1999; however, the Supreme Court reversed the CA’s ruling on August 18, 2004, reinstating the 1994 decision.
- A writ of execution was issued on November 14, 2005 to enforce the judgment.
- Contempt Proceedings
- Petition for Contempt
- On May 5, 2008, McDonald’s filed a Petition for Contempt against L.C. Big Mak Burger, Inc. and Francis Dy alleging that:
- Despite being served with the writ of execution, the petitioner continued using “Big Mak” in its restaurants.
- Petitioner's Response and Subsequent Trial Court Decision
- In its Answer with Compulsory Counterclaims, the petitioner contended that it had:
- Offered and tendered payment through the sheriff, which was refused by the respondent.
- On April 7, 2014, RTC-Makati Branch 59 rendered a decision in favor of the petitioner, dismissing the contempt petition and awarding damages to the petitioner for business reputation and moral damages.
- Appellate Review
- The CA reversed the April 7, 2014 decision by finding the petitioner guilty of indirect contempt, imposing a fine of P30,000.00, and enjoining it to comply with the Supreme Court’s earlier decision.
- The petitioner’s motion for reconsideration was denied by the CA on July 26, 2017.
- Supreme Court’s Focus in the Current Contempt Issue
- The only issue before the Supreme Court is whether the petitioner is guilty of indirect contempt for allegedly disobeying the injunction order.
- Evidence presented included testimonial and documentary proof (e.g., photographs) showing the rebranding from “Big Mak” to “Super Mak” and the continued use of the corporate name.
- The petitioner also relied on a binding SEC decision (dated January 3, 1994) that supported its use of its corporate name, arguing such use complied with the injunction.
Issues:
- Whether or not the petitioner, L.C. Big Mak Burger, Inc., is guilty of indirect contempt.
- Did the petitioner willfully disregard or violate the court’s injunction by continuing to use “Big Mak” in any form?
- Does the use of the corporate name “L.C. Big Mak Burger, Inc.,” which contains the disputed words, constitute a violation of the injunction that solely proscribed the conflicting mark?
- How does the evidence (including testimonial affidavits and photographs) reflect on the petitioner’s compliance or non-compliance with the court’s order?
- To what extent does the petitioner’s reliance on the SEC decision justify its actions under the injunction order?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)