Case Digest (G.R. No. 183719) Core Legal Reasoning Model
Facts:
The case involves the Philippine Education Company, Inc. as the plaintiff and appellee, against Vicente Sotto and V. R. Alindada, with V. R. Alindada as the appellant. The dispute arose from the publication of an article originally published by the plaintiff’s magazine without an explicit copyright but accompanied by a notice reserving all rights regarding the publication of the article. The defendant reproduced the article in his own magazine without citing the source of the reproduction. The plaintiff had purchased the article and had given notice to the defendant that it reserved all rights to the article’s publication and warned against infringement. The defendants argued that since the article was published without copyright, it had become public property, and they could legally republish it without citing the source. The lower court ruled in favor of the plaintiff, and the defendant appealed. The primary legal question was the interpretation of Act No. 3134, the Copyright
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Case Digest (G.R. No. 183719) Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Case
- Philippine Education Company, Inc. (Plaintiff and Appellee) sued Vicente Sotto and V. R. Alindada (Defendants; with Alindada as Appellant).
- The case involves the alleged unauthorized publication of an article originally published by the plaintiff.
- Statutory Framework
- The dispute centers on the interpretation of Act No. 3134, the Copyright Law of the Philippine Islands.
- Section 2 of the Act defines materials subject to copyright (including books, manuscripts, commentaries, etc.).
- Section 4 states that anonymous or pseudonymous writings are the property of the publishers.
- Section 5 discusses permissible quotation and reproduction:
- First paragraph limits quotation to copyrighted works for comment, dissertation, or criticism.
- Second paragraph allows reproduction of news items, editorial paragraphs, and articles in periodicals unless there is a notice reserving publication rights or copyright notice, but requires citing the source.
- The article at issue was published by plaintiff without copyright registration but with a reservation of rights notice: "we reserve all rights."
- Defendant’s Contentions
- Defendant argued that once published without copyright, the article became public property.
- Therefore, the defendant claimed a legal right to republish it without citing the source.
- The defendant referenced U.S. copyright law, where similar publication without copyright renders a work public domain.
- Plaintiff’s Position and Court’s Observation
- Plaintiff bought and paid for the article and published it with a reservation notice.
- Defendant republished the article without citing the source or respecting the reservation of rights.
- The court noted that unlike U.S. law, the Philippine Act specifically requires citation of the source even when no copyright notice exists, if publication is reserved.
- The article was not copyrighted but was accompanied by a notice reserving publication rights, triggering protection under the Act.
Issues:
- Whether the article, published without copyright registration but with a reserved rights notice, became public property and could be republished without citing the source under Philippine copyright law.
- The correct legal construction of the second paragraph of Section 5 of Act No. 3134 regarding reproduction of news items, editorials, and articles in periodicals published without copyright but with a reservation notice.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)