Title
Sasot vs. People
Case
G.R. No. 143193
Decision Date
Jun 29, 2005
The Supreme Court upholds the denial of the motion to quash, stating that certiorari is not the appropriate remedy and that the complainant's capacity to sue is irrelevant in public crimes like unfair competition, remanding the case for further proceedings.
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Case Digest (G.R. No. 143193)

Facts:

  • Melbarose R. Sasot and Allandale R. Sasot (petitioners) are involved in a legal dispute against the People of the Philippines, the Court of Appeals, and Rebecca G. Salvador, Presiding Judge of the Regional Trial Court (RTC) of Manila, Branch 1 (respondents).
  • The case originated in May 1997 when the National Bureau of Investigation (NBI) began investigating a complaint from NBA Properties, Inc., a U.S.-based foreign corporation, alleging that the petitioners were engaged in unfair competition by selling counterfeit NBA merchandise.
  • The NBI's report confirmed that NBA Properties, Inc. owned various trademarks related to NBA teams and that the petitioners were producing counterfeit items.
  • On October 7, 1997, Rick Welts, President of NBA Properties, Inc., executed a Special Power of Attorney to authorize a law firm to act on behalf of the company.
  • A Complaint-Affidavit was filed on February 12, 1998, leading to a recommendation for prosecution on July 15, 1998.
  • The Information accused the petitioners of unlawfully manufacturing and selling garments that misled the public into believing they were authentic NBA products, violating Article 189 of the Revised Penal Code.
  • Before arraignment, the petitioners filed a Motion to Quash the Information, claiming the facts did not constitute an offense and that the RTC lacked jurisdiction.
  • The RTC denied their motion on March 5, 1999, prompting the petitioners to file a special civil action for certiorari with the Court of Appeals, which was dismissed on January 26, 2000.
  • Their motion for reconsideration was also denied, leading to a petition for review on certiorari under Rule 45 of the Rules of Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition for lack of merit, affirming the decisions of the lower courts.
  • The Court held that a special civil action for certiorari was not the proper remedy to challenge the denial of a motion to quash an i...(Unlock)

Ratio:

  • The Court emphasized that a special civil action for certiorari is not suitable for contesting the denial of a motion to quash an information.
  • The proper action for the accused is to enter a plea and proceed to trial, where defenses can be raised.
  • The Court noted that the petitioners' arguments regarding defects ...continue reading

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