G.R. No. 213815 - Medina vs. Global Quest Ventures, Inc.

Global Quest Ventures, Inc. (Global) is a domestic corporation manufacturing and selling gulaman jelly powder. It used the name and logo “Mr. Gulaman” on product packaging and obtained a Certificate of Copyright Registration for the mark in 1996 in the name of its designer, Benjamin Irao, Jr. A Deed of Assignment dated February 14, 2005 transferred all rights in the copyrighted mark from Irao to Global. Global had been using the mark in commerce since 2000.
Ma. Sharmaine R. Medina filed an application on May 9, 2005 to register the stylized mark “Mr. Gulaman” under Class 29 of the Nice Classification. Despite Global’s opposition, registration issued in Medina’s name on June 25, 2006 (Certificate No. 4-2005-004181).

Global filed a Petition for Cancellation before the Intellectual Property Office (IPO), alleging Medina’s registration was obtained fraudulently and contrary to the Intellectual Property Code, and presenting evidence of Global’s prior use: product samples, the copyright certificate, the 2005 Deed of Assignment, sales invoices, and Irao’s affidavit.
IPO Bureau of Legal Affairs (BLA-IPO) declared Medina in default for failing to answer summons, denied her motions for reconsideration, and granted the cancellation petition on August 8, 2008, finding that Medina had copied Global’s mark and that Global’s prior use and assignment vested ownership.
Medina appealed to the Office of the Director General, which on May 28, 2012 affirmed the BLA-IPO decision, emphasizing Global’s substantial evidence of prior use and ownership.
Medina then petitioned the Court of Appeals (CA). On October 31, 2013, the CA affirmed the Director General’s findings, recognizing that the prima facie presumption of Medina’s registration was overcome by Global’s evidence of prior use. Medina’s motion for reconsideration was denied on August 8, 2014.
Medina filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, raising issues of presumed ownership, evidence admissibility, and alleged denial of due process.

Whether the Court of Appeals erred in affirming the cancellation of Medina’s Certificate of Registration No. 4-2005-004181 on the ground that Global overcame the prima facie presumption of Medina’s ownership by showing prior use.
Whether the alleged irregularity in admitting only photocopies of Global’s documentary evidence and the IPO’s declaration of Medina in default deprived Medina of due process and warrants reversal.