G.R. No. 131522 - Habana vs. Robles

Case Summary (G.R. No. 131522)

Petitioners, Respondents, Key Dates and Applicable Law

Petitioners: Habana, Cinco, Fernando
Respondents: Robles, Goodwill Trading Co., Inc.
Key Dates:

Demand to cease infringement: 1985–1987
Complaint filed in RTC Makati: July 7, 1988
Trial court decision: April 23, 1993
Court of Appeals decision: June 27, 1997
Supreme Court decision: July 19, 1999
Applicable Law: 1987 Constitution (Art. XVI, Sec. 10 on intellectual property), Presidential Decree No. 49 (in force at time of filing), and principles echoed in Republic Act No. 8293 (Intellectual Property Code).

Facts

Petitioners discovered in 1985 that DEP closely mirrored CET’s text, structure, illustrations and examples. They demanded that respondents stop distribution and recall DEP; respondents refused. Petitioners filed a complaint for infringement and unfair competition, seeking destruction of infringing materials, an accounting of profits, damages and attorney’s fees. Goodwill disclaimed knowledge of infringement; Robles denied copying, attributing similarities to common subject matter, a shared academic syllabus and fair use of public domain or previously published materials.

Procedural History

The Regional Trial Court dismissed the complaint, finding no infringement under P.D. 49 and awarded attorney’s fees to respondents. Petitioners appealed to the Court of Appeals, which affirmed the dismissal but removed the award of attorney’s fees. Petitioners then moved for reconsideration before the Court of Appeals, which was denied, and subsequently filed a petition for review on certiorari under Rule 45.

Issues Presented

Did respondents commit copyright infringement despite textual, thematic and sequential similarities?
Did respondents act in bad faith by ignoring demands and continuing distribution?
Did Robles exceed fair-use allowances under Section 11 of P.D. 49?

Legal Principles and Analysis

– 1987 Constitution vests Congress with power to protect intellectual property, implemented by P.D. 49 and codified in R.A. 8293.
– Copyright grants exclusive economic rights, including reproduction and public distribution; infringement requires unauthorized copying that substantially appropriates the original.
– Similarities in works on the same subject, arising from common sources or standard syllabi, do not alone prove infringement.
– Fair use permits quotation and limited reproduction for scientific, critical, educational or research purposes, provided source and author are credited.
– Substantial reproduction exists if enough of the original work is taken to diminish its value or usurp the author’s labor.

Supreme Court’s Ruling

The Court found that

Case Syllabus (G.R. No. 131522)

Facts of the Case

Petitioners are co-authors and registered copyright owners of three college English textbooks collectively titled “College English for Today” (Books 1 and 2) and “Workbook for College Freshman English, Series 1.”
Respondent Felicidad C. Robles authored and, with respondent Goodwill Trading Co., Inc. as publisher/distributor, released “Developing English Proficiency” (Books 1 and 2, 1985).
Petitioners discovered in bookstores that DEP closely mirrored CET in contents, structure, illustrations, examples and sequence of topics.
After itemized comparison, petitioners concluded that substantial portions of DEP were copied or plagiarized from CET, prompting demands to cease distribution and for damages.

Complaint and Trial Court Proceedings

On July 7, 1988, petitioners filed a complaint for infringement and/or unfair competition with damages in the Regional Trial Court, Makati (Civil Case No. 88-1317).
Petitioners sought:
- Destruction of all infringing copies of DEP, including printing materials;
- An accounting of DEP sales and proceeds;
- Compensation for actual, moral and exemplary damages, and attorney’s fees.
Goodwill Trading Co., Inc. answered, disclaiming knowledge of infringement and invoking an agreement shifting liability solely to Robles.
Robles denied copying, asserting independent research, adherence to common pedagogical syllabi (APCAS), and fair-use of materials as guide.
A bill of particulars was filed and complied with, identifying the exact pages and lines allegedly reproduced.

Trial Court Decision

After pre-trial stipulation of facts and trial on the merits, RTC Branch 36 (Presiding Judge Marvie R. Abraham Singson) rendered judgment on April 23, 1993:
- Dismissed petitioners’ complaint for infringement and/or unfair competition.
- Ordered petitioners to pay attorney’s fees: ₱20,000 to Robles and ₱5,000 to Goodwill.
- Petitioners were cast for costs.

Appeal to the Court of Appeals

Petitioners appealed; records forwarded on July 19, 1993.
They argued the trial court ignored their itemized evidence and wrongly found bad faith.
On June 27, 1997, the Court of Appeals (CA-G.R. CV No. 44053) affirmed the RTC decision but deleted the attorney’s-fees awards, finding no bad faith on petitioners’ part.
CA held that similarity alone does not prove infringement where both works derive from common sour