Case Digest (G.R. No. 160054-55)
Facts:
In Manolo P. Samson v. Hon. Reynaldo B. Daway, petitioner Manolo P. Samson, the registered owner of ITTI Shoes, was charged on March 7, 2002 by the People of the Philippines and Caterpillar, Inc. with unfair competition under Section 168.3(a), in relation to Section 170 of the Intellectual Property Code (Republic Act No. 8293). The informations alleged that during the first week of November 1999 in Quezon City, Samson willfully sold footwear and accessories bearing trademarks and designs confusingly similar to those of Caterpillar, thereby prejudicing the latter’s prior rights. On April 19, 2002, petitioner moved to suspend his arraignment, invoking a “prejudicial question” pending in Civil Case No. Q-00-41446 and a petition for review of the Chief State Prosecutor’s resolution finding probable cause. The Regional Trial Court (RTC), Branch 90, Quezon City, denied that motion by Order of August 9, 2002. On August 20, 2002, Samson filed a motion to quash the informations and a motCase Digest (G.R. No. 160054-55)
Facts:
- Charged Offense
- On March 7, 2002, two informations for unfair competition under Section 168.3(a) in relation to Section 170 of the Intellectual Property Code (R.A. No. 8293) were filed against petitioner Manolo P. Samson, owner of ITTI Shoes.
- The accusatory portion alleged distribution and sale of colorable imitations of Caterpillar products, causing public confusion and damage to Caterpillar, Inc.
- Pre-trial Motions
- April 19, 2002 – Petitioner moved to suspend arraignment and proceedings, citing a prejudicial question in Civil Case No. Q-00-41446 and a pending petition for review with the Secretary of Justice contesting probable cause.
- August 9, 2002 – The RTC Branch 90 denied the motion to suspend arraignment.
- August 20, 2002 – Petitioner filed a motion to quash the informations and for reconsideration of the denial to suspend, arguing lack of RTC jurisdiction given penalty not exceeding six years (R.A. No. 7691).
- Trial Court and Supreme Court Proceedings
- March 26, 2003 – RTC denied the motion to quash and the motion for reconsideration.
- August 5, 2003 – RTC denied reconsideration of the March 26 Order.
- Petitioner filed a petition for certiorari before the Supreme Court, alleging grave abuse of discretion by the RTC judge.
Issues:
- Jurisdiction
- Which court has jurisdiction over criminal and civil cases for violations of intellectual property rights?
- Suspension of Arraignment
- Whether the RTC judge gravely abused discretion by refusing to suspend arraignment on the ground of a prejudicial question arising from a parallel civil case.
- Whether the RTC judge gravely abused discretion by refusing to suspend arraignment due to the pendency of a petition for review with the Secretary of Justice.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)