G.R. No. 78413 - Cagayan Valley Enterprises, Inc. vs. Court of Appeals

La Tondea, Inc. (LTI) registered 350 c.c. white flint bottles with the Philippine Patent Office in 1953, renewing the registration in 1974.
On November 10, 1981, LTI filed a civil case against Cagayan Valley Enterprises, Inc. (Cagayan) for using its registered bottles without consent, violating Republic Act No. 623.
LTI sought a preliminary injunction to prevent Cagayan from using the bottles, which the court granted temporarily on November 16, 1981.

Cagayan argued that LTI had no cause of action due to failure to display required registration notices.
Cagayan contended that LTI's products, being hard liquor, were not protected under Republic Act No. 623.
Cagayan claimed that LTI did not reserve ownership of the bottles in sales invoices and that it used its own labels, not infringing on LTI's rights.

After a lengthy trial, the trial court ruled in favor of Cagayan, stating that LTI's complaint did not establish a cause of action and awarded damages to Cagayan.
LTI appealed the decision to the Court of Appeals.

The Court of Appeals reversed the trial court's decision, permanently enjoining Cagayan from using LTI's registered bottles and awarding damages to LTI.
Cagayan's motion for reconsideration was denied, prompting the current petition for review.

Republic Act No. 623 outlines the registration and protection of marked bottles and containers, prohibiting unauthorized use without written consent.
The law provides for civil and criminal actions against violators, emphasizing the protection of registered marks.

Cagayan's assertion that the absence of "property of" on the bottles negated LTI's registration was rejected; the law only requires the manufacturer's name or marks.
The Court found that hard liquor falls under the definition of "other lawful beverages," thus protected by Republic Act No. 623.

The Court determined that the omission of "property of" did not invalidate LTI's ownership claim, as the bottles were still identifiable as LTI's.
The registration of LTI's bottles was upheld, confirming that Cagayan's use constituted a violation of LTI's rights.

Cagayan's claim of good faith was dismissed; evidence showed that it had actual knowledge of LTI's registered marks.
The prior admission in a related case established that Cagayan was aware of the registration status of the bottles.

The Court examined the relationship between Cagayan and the former Cagayan Valley Distillery, concluding they were essentially the same entity.
The corporate...continue reading