Case Digest (G.R. No. L-44444-45) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rosario C. Maguan (formerly Rosario C. Tan) v. The Honorable Court of Appeals and Susana Luchan (230 Phil. 204, November 28, 1986), petitioner Rosario C. Maguan, doing business as “Swan Manufacturing,” holds three utility model patents on powder puffs: UM-423 (extended under UM-109), UM-450 (extended under UM-110), and UM-1184. In July 1974, Maguan wrote private respondent Susana Luchan, who marketed “Susana Luchan Powder Puff,” demanding she stop making and selling allegedly infringing powder puffs or face judicial action. Luchan replied that her products differed and that Maguan’s patents were void for lack of novelty and improper authorship. She then filed three cancellation petitions before the Philippine Patent Office. On August 24, 1974, Maguan sued for patent infringement in the Court of First Instance of Rizal, Pasig Branch (Civil Case No. 19908), and secured a preliminary injunction in September 1974 enjoining Luchan from manufacturing or selling the powder puffs. Lu Case Digest (G.R. No. L-44444-45) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Patents
- Petitioner Rosario C. Maguan (formerly Tan) conducts business as “SWAN MANUFACTURING” and holds three utility-model patents:
- UM-423 (extended under UM-109, 5 years from October 6, 1971)
- UM-450 (extended under UM-110, 5 years from January 26, 1972)
- UM-1184 (5 years from April 5, 1974)
- Private respondent Susana Luchan operates as “SUSANA LUCHAN POWDER PUFF MANUFACTURING.”
- Pre-litigation Correspondence and Cancellation Petitions
- July 10, 1974 – Petitioner demands cessation of alleged infringing powder-puff manufacturing and sales.
- Respondent denies infringement, challenges patent validity as void for lack of novelty and erroneous inventorship.
- July 25, 1974 – Respondent files inter partes cancellation petitions before the Philippine Patent Office against UM-109, UM-110, and UM-1184.
- Trial Court Proceedings (Civil Case No. 19908, CFI Rizal, Pasig)
- August 24, 1974 – Petitioner sues for damages and seeks preliminary injunction for patent infringement.
- September 18, 1974 – Trial court grants preliminary injunction enjoining respondent from making, using, or selling products embodying the patented models.
- September 11, 1975 – Trial court denies respondent’s motion for reconsideration of the injunction order.
- Court of Appeals Proceedings (CA-G.R. No. SP-04706)
- September 29, 1975 – Respondent petitions for certiorari, praying to enjoin enforcement of the trial court’s orders.
- October 15, 1975 – CA issues writ enjoining enforcement of the injunction and related orders.
- February 16, 1976 – CA Decision dismisses certiorari petition, sets aside injunction for lack of grave abuse of discretion.
- July 6, 1976 – On reconsideration, CA Resolution reverses itself, reinstates and makes permanent the preliminary injunction.
- November 4, 1976 – CA denies further motion for reconsideration, affirming the July 6 Resolution.
- Supreme Court Review
- December 3, 1976 – SC requires respondent’s comment; briefs are thereafter submitted.
- May 30, 1977 – Petition for review on certiorari is given due course.
- December 9, 1977 – Case submitted for decision.
Issues:
- Jurisdiction
- Whether a trial court in an infringement suit may determine the validity or invalidity of patents pending cancellation in the Patent Office.
- Preliminary Injunction
- Whether the trial court committed grave abuse of discretion in issuing a preliminary injunction despite a fair question as to patent validity.
- Certiorari Remedy
- Whether certiorari was the proper remedy to assail the trial court’s injunctive orders given the alleged inadequacy of appeal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)