Case Digest (G.R. No. 108000) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lyceum of the Philippines, Inc. v. Court of Appeals et al. (G.R. No. 101897, March 5, 1993), the petitioner, Lyceum of the Philippines, Inc., is an educational corporation first registered with the Securities and Exchange Commission (SEC) on September 21, 1950. It sought to enjoin a number of private educational institutions—Western Pangasinan Lyceum (incorporated October 27, 1950), Lyceum of Cabagan (October 31, 1962), Lyceum of Lallo, Inc. (March 26, 1972), Lyceum of Aparri (March 28, 1972), Lyceum of Tuao, Inc. (March 28, 1972), Lyceum of Camalaniugan (March 28, 1972), Buhi Lyceum, Central Lyceum of Catanduanes, Lyceum of Southern Philippines, and Lyceum of Eastern Mindanao, Inc.—to delete the word “Lyceum” from their names. The petitioner had earlier prevailed in an SEC hearing officer’s ruling (SEC-Case No. 1241) against Lyceum of Baguio, Inc., which was affirmed by this Court in G.R. No. L-46595 (Entry of Judgment October 21, 1977). Relying on that precedent, the petiti Case Digest (G.R. No. 108000) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petitioner’s corporate identity and registration
- Lyceum of the Philippines, Inc. registered with the SEC on 21 September 1950 under that name.
- On 24 February 1984, petitioner filed SEC-Case No. 2579 to compel private respondents to delete “Lyceum” from their corporate names and enjoin further use.
- Private respondents and procedural history
- Active respondents (with original SEC registration dates):
- Western Pangasinan Lyceum – 27 October 1950
- Lyceum of Cabagan – 31 October 1962
- Lyceum of Lallo, Inc. – 26 March 1972
- Lyceum of Aparri – 28 March 1972
- Lyceum of Tuao, Inc. – 28 March 1972
- Lyceum of Camalaniugan – 28 March 1972
- Defaulted respondents (failed to answer): Buhi Lyceum; Central Lyceum of Catanduanes; Lyceum of Eastern Mindanao, Inc.; Lyceum of Southern Philippines.
- Three other entities were initially included but later dropped or dismissed: Lyceum of Malacanay; Lyceum of Marbel; Lyceum of Araullo.
- Prior SEC proceedings and appeals
- SEC Case No. 1241 vs. Lyceum of Baguio, Inc. (Order of 20 April 1977): held “Lyceum” a dominant word; Baguio school ordered to change name; Supreme Court denied review (G.R. L-46595, 14 September 1977).
- SEC-Case No. 2579 hearing officer ruled in favor of petitioner’s exclusive right to “Lyceum.”
- SEC En Banc reversed the hearing officer, finding no public confusion due to geographic modifiers.
- Court of Appeals (Decision 28 June 1991) affirmed the SEC En Banc; motion for reconsideration denied.
Issues:
- Whether the Supreme Court’s Minute Resolution in G.R. No. L-46595 is binding as stare decisis on the right to exclusive use of “Lyceum.”
- Whether the Court of Appeals erred in determining that Western Pangasinan Lyceum was incorporated prior to petitioner.
- Whether the word “Lyceum” acquired a secondary meaning in favor of petitioner.
- Whether a generic term like “Lyceum” can be appropriated exclusively by petitioner.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)