Case Digest (G.R. No. 96161) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philips Export B.V., Philips Electrical Lamps, Inc. and Philips Industrial Development, Inc. (collectively “Petitioners”), a foreign corporation organized under Dutch law holding Philippine registrations for the PHILIPS and PHILIPS SHIELD EMBLEM trademarks since 1922 (Certificate Nos. R-1641, R-1674, R-1651), along with its authorized Philippine subsidiaries incorporated in 1956, filed on 24 September 1984 a complaint with the Securities and Exchange Commission (SEC) to cancel the use of the word “PHILIPS” in Standard Philips Corporation’s corporate name. Standard Philips had secured its charter on 19 May 1982. Upon refusal to amend, Petitioners lodged SEC Case No. 2743 on 6 February 1985, seeking a Writ of Preliminary Injunction and removal of “PHILIPS” for alleged infringement of their exclusive right. Private Respondent countered that it had legal capacity to use its corporate name, that its business in chain rollers, belts and machinery parts did not overlap with Petition Case Digest (G.R. No. 96161) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Petitioners
- Philips Export B.V. (PEBV) – foreign corporation, owner since 1922 of trademarks “PHILIPS” (Reg. No. R-1641) and “PHILIPS SHIELD EMBLEM” (Reg. No. R-1674).
- Philips Electrical Lamps, Inc. and Philips Industrial Development, Inc. – Philippine corporations incorporated in 1956 as authorized users of the PHILIPS trademarks; members of the PHILIPS Group of Companies.
- Respondent
- Standard Philips Corporation – Philippine corporation registered with SEC on 19 May 1982, incorporating “PHILIPS” in its corporate name.
- Trademark and Corporate Name Registrations
- Trademark Registrations
- PHILIPS (1922) and PHILIPS SHIELD EMBLEM (1922) – PEBV’s exclusive marks registered with Philippine Patent Office.
- Denial of Standard Philips’ application for “Standard Philips & Device” covering chains, rollers, belts, bearings, cutting saw (Inter Partes Case No. 2010, 1988).
- Corporate Name Registrations
- Petitioners’ AICs – Philips Electrical and Philips Industrial registered with SEC in August and May 1956.
- Standard Philips’ AIC – registered 19 May 1982, articles include broad powers to deal in electrical supplies and mechanical goods.
- Proceedings Before the SEC and the Court of Appeals
- SEC Proceedings (SEC-AC No. 202; Case No. 2743)
- September 1984 – petitioners lodged letter-complaint asking for cancellation of “PHILIPS” in Standard Philips’ name.
- February 1985 – petition for preliminary injunction; respondent opposed, asserting distinct business lines and lack of similarity.
- September 1985 – Hearing Officer denied injunction; January 1987 – dismissed petition on merits for lack of confusing similarity under Sec. 18, Corp. Code.
- June 1987 – SEC en banc affirmed dismissal, finding no likelihood of confusion in corporate names.
- Court of Appeals (CA-GR Sp. No. 20067)
- February 1990 – petition for certiorari elevated to CA.
- July 1990 – CA dismissed petition, distinguishing Converse Rubber doctrine on similarity and holding product lines non-competing.
- November 1990 – CA denied motion for reconsideration.
- Supreme Court Proceedings
- April 1991 – Supreme Court gives due course to petition; memoranda filed by parties, latest July 1991.
- December 1991 – SEC records elevated to Supreme Court for complete review.
Issues:
- Whether respondent Standard Philips’ use of “PHILIPS” in its corporate name violates petitioners’ prior rights in the PHILIPS trademarks and corporate names as protected under Section 18 of the Corporation Code.
- Whether confusing similarity exists between petitioners’ corporate names/trademarks and respondent’s corporate name, warranting injunctive relief even without proof of actual confusion.
- Whether the SEC and CA erred in applying corporate-name guidelines (requiring two different words) over the superior statutory protection afforded to trademarks and trade names.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)