Case Summary (G.R. No. 101897)
Petitioner
An educational institution claiming proprietary right to the word “Lyceum” and seeking injunctive relief to bar others from using that term in corporate names.
Respondents
Eleven schools using “Lyceum” plus local designations. Notably, Western Pangasinan Lyceum first registered October 27, 1950—seventeen years before some petitioner-claimed uses.
Key Dates
– September 21, 1950: Petitioner’s original SEC registration.
– April 20, 1977: SEC Associate Commissioner orders Lyceum of Baguio, Inc. to change its name (SEC-Case No. 1241).
– September 14 & October 21, 1977: Supreme Court denies and enters judgment in review of SEC order.
– February 24, 1984: Petitioner files SEC-Case No. 2579 to enjoin use of “Lyceum” by other entities.
– June 28, 1991: Court of Appeals affirms SEC En Banc reversal.
– March 5, 1993: Supreme Court Decision rendered.
Applicable Law
– 1987 Philippine Constitution (governing corporate charters post-1990).
– Corporation Code, Sec. 18: prohibits corporate names identical, deceptively or confusingly similar to existing ones.
– Trademark doctrine of secondary meaning as applied to corporate names.
Procedural History
- Petitioner successfully challenged Lyceum of Baguio, Inc.’s use of “Lyceum” before SEC (SEC-Case No. 1241) and the Supreme Court denied review.
- After unsuccessful private negotiations, petitioner filed SEC-Case No. 2579 to secure exclusive right to “Lyceum.”
- SEC hearing officer granted exclusivity; SEC En Banc reversed, finding geographic qualifiers sufficient to prevent confusion.
- Court of Appeals affirmed; petitioner’s motion for reconsideration denied.
- Petitioner elevated the case to the Supreme Court.
Issues Presented
- Whether the prior Supreme Court resolution (G.R. No. L-46595) on Lyceum of Baguio, Inc. constitutes binding precedent or res judicata.
- Whether Western Pangasinan Lyceum’s earlier registration precludes petitioner’s claim of priority.
- Whether “Lyceum” has acquired secondary meaning in favor of petitioner.
- Whether a generic term like “Lyceum” is appropriable exclusively by one entity.
Analysis
– The 1977 Minute Resolution lacks the identity of parties and is not a reasoned opinion; it does not operate as res adjudicata or binding stare decisis on new parties.
– Under Corporation Code Sec. 18, corporate names must not be identical or confusingly similar; the entire corporate name must be compared, not merely the shared word.
– Etymology and usage establish “Lyceum” as a generic term for educational institutions (akin to “university”); widespread use (including by Roman Catholic “Liceo” schools) predates and parallels petitioner’s use.
– Doctrine of secondary meaning requires long, exclusive use by one entity, creating public association of the term with that entity. Here, p
Case Syllabus (G.R. No. 101897)
Facts
- Petitioner, Lyceum of the Philippines, Inc., is a corporation duly registered with the SEC on 21 September 1950 under that name.
- On 24 February 1984, petitioner filed SEC‐Case No. 2579 to compel private respondents—various educational institutions—to delete “Lyceum” from their corporate names.
- Active respondents and their original SEC registration dates:
- Western Pangasinan Lyceum – 27 October 1950
- Lyceum of Cabagan – 31 October 1962
- Lyceum of Lallo, Inc. – 26 March 1972
- Lyceum of Aparri – 28 March 1972
- Lyceum of Tuao, Inc. – 28 March 1972
- Lyceum of Camalaniugan – 28 March 1972
- Four respondents were in default for failure to answer: Buhi Lyceum; Central Lyceum of Catanduanes; Lyceum of Eastern Mindanao, Inc.; Lyceum of Southern Philippines.
- Petitioner’s prior SEC‐Case No. 1241 forced Lyceum of Baguio, Inc. to change its name in 1977; this was upheld by the Supreme Court in G.R. No. L‐46595 on 14 September 1977.
- Hearing officer in SEC‐Case No. 2579 ruled in petitioner’s favor, recognizing an exclusive right to the word “Lyceum.”
- SEC En Banc reversed, finding geographic qualifiers prevented public confusion and that “Lyceum” remained generic.
- Court of Appeals affirmed the SEC En Banc decision on 28 June 1991; motion for reconsideration denied.
Procedural History
- SEC‐Case No. 2579:
- Decision by hearing officer sustaining petitioner’s claim
- Reversal by SEC En Banc
- Appeal to the Court of Appeals:
- Decision dated 28 June