Case Digest (G.R. No. 195835) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 195835, decided on March 14, 2016 under the 1987 Constitution, petitioners Sison Olaao, Sergio T. Ong, Marilyn O. Go and Jap Fuk Hai, officers and directors of Metrotech Steel Industries, Inc., were charged with copyright infringement by respondent Lim Eng Co., Chairman of LEC Steel Manufacturing Corporation. In 2002, LEC submitted to the architects of the Manansala Project in Rockwell Center, Makati City, shop plans and later final drawings (January 15, 2004) for interior and exterior hatch doors, which were approved for construction (February 3, 2004). LEC then installed doors on floors 7–22, while Metrotech was later engaged to install similar doors on floors 23–41. After LEC secured certificates of copyright registration (Nos. 1-2004-13/14 on July 6, 2004, and Nos. H-2004-566/567 on December 9, 2004) and demanded cessation of alleged infringement, the NBI obtained and executed a search warrant on Metrotech’s plant (August 13, 2004) but the RTC quashed it (Septemb Case Digest (G.R. No. 195835) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioners Sison Olaao, Sergio T. Ong, Marilyn O. Go and Jap Fuk Hai are officers/directors of Metrotech Steel Industries, Inc.
- Respondent Lim Eng Co is Chairman of LEC Steel Manufacturing Corporation, which specializes in architectural metal manufacturing.
- Manansala Project and Design Submissions
- In 2002, LEC was invited to submit shop plans/drawings for interior and exterior hatch doors of the Manansala Project in Rockwell Center, Makati City; final plans were approved on February 3, 2004.
- LEC manufactured and installed hatch doors for floors 7–22; later, Metrotech was subcontracted to install hatch doors for floors 23–41 based on the same drawings.
- Copyright Registration and Demand to Cease
- On June 24, 2004, LEC demanded Metrotech stop infringing its intellectual property; Metrotech insisted no infringement occurred because it followed SKI-FB’s provided drawings.
- On July 2, 2004, LEC deposited its final shop plans/drawings with the National Library and received Certificates of Copyright Registration:
- Nos. 1-2004-13 (interior) and 1-2004-14 (exterior) under Section 172(i) for architectural plans.
- Nos. H-2004-566 and H-2004-567 under Section 172(h) for ornamental designs.
- Criminal and Preliminary Investigation
- August 13, 2004: NBI obtained a warrant, seized hatch doors and machines; same day, LEC filed a Complaint-Affidavit for copyright infringement with the DOJ; RTC quashed warrant on September 8, 2004.
- DOJ Resolutions:
- August 18, 2005 – investigating prosecutor dismissed complaint for lack of probable cause.
- November 16, 2005 – DOJ denied LEC’s petition for review.
- January 27, 2006 – DOJ reversed dismissal, found probable cause and directed filing of information.
- March 10, 2006 – DOJ granted petitioners’ reconsideration, found no probable cause, ordered withdrawal of information.
- May 25, 2006 – DOJ denied LEC’s motion for reconsideration, finalizing dismissal.
- Court of Appeals Proceedings
- July 9, 2010 – CA granted LEC’s certiorari petition, found DOJ’s vacillating resolutions capricious, reinstated January 27, 2006 resolution (probable cause).
- February 24, 2011 – CA denied petitioners’ reconsideration, leaving CA decision in place.
- Supreme Court Petition
- Petitioners filed a Rule 45 petition arguing:
- No evidence of actual reproduction of plans during preliminary investigation.
- Certificates cover only illustrations/plans, not the doors themselves.
- Manufacturing hatch doors is not copyright infringement.
- Registration certificates are not conclusive proof of copyrightability.
Issues:
- Procedural and Scope of Review
- Whether the CA erred in finding grave abuse of discretion by the DOJ in directing withdrawal of the information.
- Whether judicial review of DOJ resolutions on probable cause is limited to grave abuse of discretion.
- Substantive Copyright Infringement
- Whether manufacturing hatch doors based on LEC’s drawings constitutes reproduction under Section 177 of R.A. No. 8293.
- Whether hatch doors, as utilitarian articles, are copyrightable or if only their separable design elements may be protected.
- Whether Certificates of Copyright Registration create conclusive proof of copyrightability and ownership.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)