Facts:

The case involves the plaintiffs Western Equipment and Supply Company, Western Electric Company, Inc., W. Z. Smith, and Felix C. Reyes against the defendants Fidel A. Reyes, Henry Herman, Peter O'Brien, Manuel B. Diaz, Felipe Mapoy, and Artemio Zamora. The events leading to the case began on May 4, 1925, when the Western Equipment and Supply Company, a foreign corporation organized under Nevada law, applied for a business license in the Philippines. A provisional license was granted on May 20, 1926, and made permanent on August 23, 1926. The Western Electric Company, Inc., another foreign corporation organized under New York law, manufactured electrical and telephone apparatus that had gained a strong reputation globally, including in the Philippines.

On October 15, 1926, the defendants filed articles of incorporation to establish a domestic corporation under the name "Western Electric Company, Inc." The plaintiffs contended that this was an attempt to mislea...

Facts:

1. Parties Involved:

   • Plaintiffs: Western Equipment and Supply Company (a foreign corporation organized under Nevada law), Western Electric Company, Inc. (a foreign corporation organized under New York law), W. Z. Smith, and Felix C. Reyes.
   • Defendants: Fidel A. Reyes (Director of the Bureau of Commerce and Industry), Henry Herman, Peter O'Brien, Manuel B. Diaz, Felipe Mapoy, and Artemio Zamora.

2. Business Operations:

   • Western Equipment and Supply Company was granted a provisional license to operate in the Philippines on May 20, 1926, which became permanent on August 23, 1926. It imported and sold electrical and telephone apparatus manufactured by Western Electric Company, Inc.
   • Western Electric Company, Inc., though not licensed to operate in the Philippines, had its products widely used in the country, with its trademark "Western Electric" registered in the U.S. since 1905.

3. Attempted Incorporation:

   • On October 15, 1926, defendants Henry Herman, Peter O'Brien, Manuel B. Diaz, Felipe Mapoy, and Artemio Zamora filed articles of incorporation to form a domestic corporation under the name "Western Electric Company, Inc." to engage in the same business as the plaintiff.

4. Protest and Legal Action:

   • Plaintiffs protested the incorporation, arguing it would mislead the public and infringe on their trademark and goodwill. The Director of the Bureau of Commerce and Industry intended to overrule the protest and issue the certificate of incorporation.
   • Plaintiffs sought a temporary and permanent injunction to prevent the issuance of the certificate and the use of the name "Western Electric Company, Inc."

5. Stipulated Facts:

   • The parties agreed on the facts, including the plaintiffs' business reputation, the defendants' knowledge of the plaintiffs' business, and the intent to use the same name for a competing domestic corporation.

Issue:

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Ruling:

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Ratio:

1. Protection of Corporate Name and Goodwill:

   • A foreign corporation's right to its corporate name and goodwill is a property right that can be asserted globally, even in jurisdictions where it does not transact business. This right is protected against unfair competition and fraud.

2. Unfair Competition:

   • The defendants' intent to use the same name for a competing domestic corporation was fraudulent and aimed at misleading the public. This constitutes unfair competition under Act No. 666.

3. Jurisdiction Over Government Officers:

   • The courts have jurisdiction to review and correct errors in the exercise of discretion by government officers, such as the Director of the Bureau of Commerce and Industry, especially when such actions facilitate fraud or abuse of power.

4. Prevention of Fraud:

   • Allowing the defendants to incorporate under the same name would deceive the public and harm the plaintiffs' reputation and goodwill. The government should not facilitate such fraudulent practices.