Title
Samson vs. Daway
Case
G.R. No. 160054-55
Decision Date
Jul 21, 2004
Samson, owner of ITTI Shoes, faced unfair competition charges for imitating Caterpillar trademarks. He sought suspension of arraignment, citing a civil case and pending petition, but the RTC retained jurisdiction, ruling no prejudicial question or grave abuse of discretion.
A

Case 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)

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