G.R. No. 138456 - People vs. Deduyo

The case arose from a confidential information that petitioner Henry Uy was engaged in manufacturing, delivering, and selling counterfeit "Marca PiAa" soy sauce, a registered trademark owned by private respondent PiAakamasarap Corporation.
Based on this information, Orlando S. Bundoc, an Intelligence Officer of the Economic Intelligence and Investigation Bureau (EIIB), obtained a search warrant on February 14, 1994, on grounds of unfair competition.
The search executed on the same date led to the seizure of 55 bottles labeled "Marca PiAa" soy sauce by Atty. Francisco R. Estavillo, an agent of the National Bureau of Investigation (NBI).
Subsequently, a criminal complaint was filed against Henry Uy in the Municipal Trial Court (MTC) of Tarlac City on March 23, 1994, for violation of Article 189 (Unfair Competition) of the Revised Penal Code.

On November 8, 1994, PiAakamasarap Corporation moved to amend the complaint to include petitioner Rosario Uy, Henry Uy’s spouse, as a co-accused, which the court granted on November 15, 1994.
The amended complaint charged both Henry and Rosario Uy with willful, unlawful, and felonious conspiracy to engage in unfair competition by passing off soy sauce of inferior quality as genuine "Marca PiAa" soy sauce to deceive the public.
After preliminary examination of prosecution witnesses, probable cause to indict the petitioners was found, resulting in a warrant of arrest issued on January 30, 1995.
Petitioners were released on cash bond on February 1, 1995, arraigned on July 10, 1995, where they pleaded not guilty, and waived the pre-trial conference on October 25, 1995. The initial trial was scheduled for November 27, 1995.

Despite an Administrative Order No. 104-96 issued in October 1996 vesting exclusive jurisdiction over violations of Articles 188 and 189 of the Revised Penal Code to the Regional Trial Courts (RTC), the MTC proceeded with trial.
During the protracted trial spanning years, several witnesses testified sporadically, including personnel from the Bureau of Food and Drug Administration and PiAakamasarap Corporation.
Petitioners’ counsel withdrew in late 1999; new counsel entered appearance in November 1999.
The prosecution rested their case in February 2000 after submitting documentary evidence, excluding some exhibits.
Petitioners filed a Motion for Leave to File Demurrer to Evidence on March 10, 2000, which the court granted. Petitioners argued insufficient evidence and challenged jurisdiction of the MTC.

The MTC denied the demurrer, citing exclusive jurisdiction of RTC over intellectual property rights violations, and forwarded the case records and ruled that the issue of jurisdiction and speedy trial be addressed in RTC.
The City Prosecutor conducted preliminary investigation and filed an Information before the RTC on July 18, 2000, charging the petitioners with violation of Article 189 of the Revised Penal Code (later amended to reflect violation of Section 168 of R.A. No. 8293, the Intellectual Property Code).
Petitioners filed a Motion to Quash the Information on grounds of violation of their constitutional right to speedy trial, alleging inordinate delay of six years and lack of subpoena notices during preliminary investigation.
The RTC denied the motion to quash on September 8, 2000, ruling delay to be partly attributable to petitioners, given their failure to timely raise jurisdictional issues and their participation in the MTC proceedings.

Petitioners filed a petition for certiorari with the Court of Appeals (CA), praying for the issuance of a temporary restraining order and preliminary injunction on the basis of denial of the right to speedy trial.
The CA dismissed the petition on March 21, 2003, ruling no proof of vexatious or oppressive delay attributable purely to the prosecution and upheld denial of motion to quash.
Petitioners sought review before the Supreme Court, reiterating their claim that the six-year delay and prosecutorial negligence amounted to denial of their right to speedy trial.

Whether or not the delay in filing the Information and conducting the trial violated the petitioners’ constitutional right to a speedy trial.
Whether the MTC had jurisdiction to try the case involving violation of intellectual property rights under Article 189 of the Revised Penal Code and R.A. No. 8293.
Whether the petitioners’ failure to timely question jurisdiction and delays estops them from raising the right to speedy trial.
Whether the prosecution’s procedural errors and inordinate delay compelled the dismissal of the case.