Title
Forietrans Manufacturing Corp. vs. Davidoff Et. Cie Sa and Japan Tobacco, Inc.
Case
G.R. No. 197482
Decision Date
Mar 6, 2017
Domestic corp. FMC accused of manufacturing counterfeit cigarettes resembling Davidoff and Mild Seven trademarks; Supreme Court upheld probable cause for trademark infringement and false designation of origin, reversing Secretary of Justice's dismissal.
A

Case Summary (G.R. No. 197482)

Petitioners

FMC is a domestic corporation with principal address in Angeles Industrial Park, Special Economic Zone, Bacolor, Pampanga, and is registered as an eco-zone export enterprise with PEZA. Agerico Calaquian, FMC’s president, denied illegal manufacture and asserted that seized cigarettes were genuine imports intended for re-export and that PEZA registration and National Tobacco Administration authorizations precluded trademark infringement.

Respondents

Davidoff and JTI are non-resident foreign corporations alleging trademark infringement and false designation of origin. They authorized local counsel to prosecute infringers and engaged BPI to investigate alleged counterfeit manufacture, storage and distribution in FMC’s warehouses.

Key Dates and Procedural Posture

Investigations and raids took place on August 4–5, 2004. Prosecutor Macabulos issued a Joint Resolution dismissing complaints on September 12, 2005. Secretary of Justice Gonzalez affirmed dismissal on February 10, 2006 and denied reconsideration on March 27, 2006. The Court of Appeals reversed on March 31, 2011 (resolution July 5, 2011). The Supreme Court rendered the decision affirmed by the CA on March 6, 2017. Applicable constitution for adjudication: the 1987 Philippine Constitution.

Applicable Law

Primary statutory law applied: Republic Act No. 8293 (Intellectual Property Code of the Philippines) — notably Section 155 (infringement), Section 169 (false designation of origin; false description or representation), and Section 170 (relating to remedies and procedural aspects). Doctrines applied include the standard for probable cause in criminal prosecutions, the separation of powers between executive and judiciary regarding preliminary investigations, and the standard for grave abuse of discretion permitting judicial review of executive determinations.

Factual Background

BPI reported that FMC’s warehouses stored counterfeit Davidoff and JTI products or colorable imitations. CIDG filed and obtained several search warrants (SW Nos. 044–048) from the RTC of San Fernando, Pampanga. Raids resulted in seizure of boxes containing raw tobacco, cigarettes, cigarette packs and reams labeled “DAGETA” and “DAGETA International,” manufacturing machinery, receptacles, paraphernalia, sales invoices and official receipts; respondents also alleged seizure of items bearing the “MILD SEVEN” and “MILD SEVEN LIGHTS” trademarks. Petitioners claimed goods were genuine Dageta imports from Germany for re-export and denied on-site manufacture or arrests.

Criminal Complaints Filed

Respondents filed three complaint-affidavits charging FMC and personnel under the IP Code: OCPSF-04-H-2047 (Davidoff infringement under Sec. 155 in relation to Sec. 170), OCPSF-04-H-2048 (false designation of origin under Sec. 169 in relation to Sec. 170 for “Made in Germany” labeling), and OCPSF-04-H-2226 (JTI infringement under Sec. 155 in relation to Sec. 170 for alleged imitation of “MILD SEVEN” marks).

Preliminary Investigation and Prosecutor’s Dismissal

On September 12, 2005, Prosecutor Macabulos dismissed the complaints. He found the informant’s affidavit (Jimmy Trocio) insufficient to show probable cause for issuance of search warrants or to support that FMC manufactured fake JTI or Davidoff products. He observed alleged inconsistencies and the absence of clear evidence of seizure of MILD SEVEN products, concluding no confusing similarity between Dageta and Davidoff, and therefore dismissed the infringement and false designation complaints.

Secretary of Justice Resolutions

Secretary Gonzalez affirmed Prosecutor Macabulos’s dismissal (February 10, 2006) and denied reconsideration (March 27, 2006). The Secretary agreed there was no confusing similarity in the names “Davidoff” and “Dageta,” found respondents failed to prove falsity of “Made in Germany” labels, and concurred that there was no proof Mild Seven products had been seized or that on-site manufacture of Mild Seven products occurred during the raids.

Court of Appeals Reversal

The CA reversed the Secretary’s resolutions, holding that Secretary Gonzalez gravely abused his discretion by resolving evidentiary matters reserved for trial and by usurping the role of the trial judge. The CA treated disputed factual questions—such as whether Mild Seven items were seized and whether packaging created a likelihood of confusion—as issues properly decided after a full trial, and therefore concluded that probable cause existed to charge petitioners.

Issues Presented to the Supreme Court

The Supreme Court was asked to determine whether the Court of Appeals erred in finding that Secretary Gonzalez committed grave abuse of discretion in finding no probable cause and whether a prima facie case existed to justify filing Informations for trademark infringement and false designation of origin under the IP Code.

Legal Standards and Separation of Powers

The SC reiterated the legal definition of probable cause for criminal filing: facts sufficient to engender a well-founded belief that a crime was committed and that the respondent is probably guilty. Only prima facie evidence is required at the preliminary stage; it does not require proof sufficient for conviction. The prosecutor and the Secretary of Justice are entrusted with determining probable cause; courts generally refrain from interfering with executive determinations except in clear cases of grave abuse of discretion—an arbitrary, capricious, or despotic exercise akin to lack of jurisdiction.

Supreme Court’s Finding of Grave Abuse by the Secretary

The SC concluded that Secretary Gonzalez committed grave abuse of discretion by failing to evaluate the evidence submitted during the preliminary investigation and by unduly focusing on the sufficiency of the search-warrant affidavits considered by the trial judge. The prosecutor likewise improperly reviewed the judicial determination that supported issuance of the search warrants. The SC emphasized that the prosecutor’s role is distinct from the judge’s and that the Secretary should evaluate the evidence presented in preliminary investigation rather than reweighing matters decided during the warrant issuance process.

Prima Facie Case on Trademark Infringement (Davidoff/Dageta)

The SC found that respondents submitted sample exhibits of authentic Davidoff packs and the Dageta packs seized, noting multiple similarities in pack design (octagonal pack design, black and red covering, silver coloring on tear tape and printing, manufacturing code on base, and similar textual formulations on the back of the pack). The Court observed that infringers frequently use colorable imitations—sufficient points of similarity to confuse consumers

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.