Case Digest (G.R. No. 63796-97) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In La Chemise Lacoste, S.A. v. Hon. Oscar C. Fernandez (G.R. Nos. L-63796-97) decided on May 21, 1984, La Chemise Lacoste, S.A., a French corporation not doing business in the Philippines and owner of the trademarks “LACOSTE,” “CHEMISE LACOSTE,” “CROCODILE DEVICE” and a composite mark, filed a letter-complaint with the National Bureau of Investigation (NBI) in March 1983 for alleged unfair competition under Article 189 of the Revised Penal Code. The NBI procured Search Warrant Nos. 83-128 and 83-129 from Judge Oscar C. Fernandez of RTC Branch XLIX, Manila, seized garments bearing the LACOSTE mark from premises owned by Gobindram Hemandas (private respondent), who had earlier secured Registration No. SR-2225 in the Supplemental Register for “CHEMISE LACOSTE & CROCODILE DEVICE.” Hemandas moved to quash the warrants on grounds of purportedly different trademarks and the pendency of Patent Office inter partes proceedings (IPC No. 1658 and 1689), and the RTC granted his motion, order Case Digest (G.R. No. 63796-97) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Trademarks
- Petitioner La Chemise Lacoste, S.A.: a French corporation, owner of the trademarks “LACOSTE,” “CHEMISE LACOSTE,” “CROCODILE DEVICE,” and a composite mark, used on clothing and sporting apparel marketed worldwide and in the Philippines since 1964.
- Respondent Gobindram Hemandas (via Hemandas & Co.): a Philippine firm that in 1975 obtained Reg. No. SR-2225 (Supplemental Register) for the mark “CHEMISE LACOSTE & CROCODILE DEVICE,” applied in 1977 to the Principal Register, and assigned all rights to Gobindram Hemandas.
- Intellectual Property Proceedings
- November 1980: La Chemise applied for Philippine registration of “CROCODILE DEVICE” (approved for publication) and “LACOSTE” (opposed by Games and Garments, IPC No. 1658).
- 1982: La Chemise filed for cancellation of Reg. SR-2225 (IPC No. 1689). Both cases reached this Court in G.R. No. 65659.
- Criminal Complaint and Search Warrants
- March 21, 1983: La Chemise filed a complaint with the NBI for unfair competition under Article 189, Revised Penal Code.
- NBI obtained Search Warrants Nos. 83-128 and 83-129 from RTC Branch XLIX; executed the warrants and seized apparel bearing the “LACOSTE” mark.
- Hemandas moved to quash the warrants on grounds that (a) his mark differed from petitioner’s and (b) the warrants were premature due to pending administrative proceedings. The RTC granted the motion, recalled the warrants, and ordered return of seized items.
- Minister of Trade Memoranda (G.R. No. 65659)
- November 20, 1980: Minister Villafuerte memo directing Patents Office to reject world-famous trademark applications by non-original owners, implementing Paris Convention art. 6bis.
- October 7, 1983: Executive Order 913 broadened Minister Ongpin’s adjudicatory powers; Ongpin issued a memorandum reiterating and expanding the 1980 directive.
Issues:
- In G.R. Nos. L-63796-97 (La Chemise petition)
- Did the RTC judge gravely abuse discretion and lack jurisdiction by reversing his own finding of probable cause and quashing valid search warrants based on matters of defense?
- Was the issuance of the search warrants premature given (a) pending Patent Office opposition/cancellation proceedings (IPC Nos. 1658, 1689) and (b) Hemandas’s registration on the Supplemental Register?
- In G.R. No. 65659 (Hemandas petition)
- Did Minister Ongpin exceed authority or violate law by issuing a memorandum directing the Patents Office to refuse or cancel registrations of world-famous trademarks under Paris Convention art. 6bis?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)