Case Summary (G.R. No. 195835)
Petitioner and Respondent Roles
• Petitioners fabricated and installed hatch doors on floors 23–41 of the Project.
• Respondent originally supplied designs, secured a subcontract for floors 7–22, and registered copyrights on shop plans and ornamental models.
Key Dates
• July 16, 2002–January 15, 2004: Submission and approval of final shop drawings by LEC.
• June 24 to July 6, 2004: LEC demands cessation, deposits drawings at National Library, obtains Certificates of Registration Nos. 1–2004–13, 1–2004–14 (plans) and H‐2004‐566, H‐2004‐567 (ornamental models).
• August 13, 2004: NBI‐assisted search, confiscation of Metrotech’s doors; DOJ complaint filed.
• August 18, 2005 to May 25, 2006: Successive DOJ resolutions dismissing, then finding probable cause, then again dismissing for lack of probable cause.
• July 9, 2010 & February 24, 2011: Court of Appeals annuls DOJ dismissal and reinstates finding of probable cause.
• March 14, 2016: Supreme Court decision under review.
Applicable Law
• 1987 Constitution (separation of powers; limited judicial review of executive discretion).
• Republic Act No. 8293 (Intellectual Property Code of the Philippines):
– Section 172(i): copyrightable subject matter includes “illustrations, maps, plans, sketches…architectural works.”
– Section 172(h): “original ornamental designs or models for articles of manufacture.”
– Section 177.1 & Section 216: acts constituting copyright infringement.
• Rules of Court, Rule 45 (certiorari).
Factual Background
LEC designed, copyrighted, and first installed interior and exterior hatch doors for a high‐end condominium. Metrotech later fabricated similar doors based on contractor‐provided drawings. LEC alleged infringement, sought investigative action, and initiated DOJ proceedings.
Preliminary Investigation and DOJ Resolutions
- Investigating Prosecutor (Aug 18, 2005): dismissed for lack of evidence that hatch doors themselves were within the registered plans or ornamental models.
- DOJ First Review (Nov 16, 2005): denied review.
- DOJ Second Review (Jan 27, 2006): reversed dismissal, found probable cause based on alleged artistic features.
- DOJ Final Resolution (Mar 10 & May 25, 2006): granted petitioners’ reconsideration, held no probable cause due to purely utilitarian nature of doors.
Court of Appeals Findings
The CA held that the DOJ’s shifting conclusions evidenced grave abuse of discretion. Applying a broad view of probable cause, it reinstated the finding that petitioners likely infringed both the plans and ornamental models by reproducing LEC’s designs without consent.
Issue for Supreme Court Review
Whether the Court of Appeals correctly annulled the DOJ’s dismissal for lack of probable cause, and whether the DOJ committed grave abuse of discretion in determining the absence of probable cause.
Supreme Court Ruling
The Supreme Court reversed the CA, reinstating the DOJ resolutions dismissing the complaint. It held that:
• Judicial review of the Secretary of Justice’s probable‐cause finding is limited to grave abuse of discretion.
• Inconsistent DOJ resolutions, standing alone, do not establish such abuse absent a gross misapprehension of facts.
Legal Reasoning
- Grave Abuse Standard: courts may only overturn executive probable‐cause determinations if exercised in a capricious, arbitrary manner betraying jurisdictional failure.
- Copyright Elements: infringement requires (a) valid ownership of a copyrighted work and (b) proof of unauthorized reproduction.
- Scope of Registration:
– Certificates 1‐2004‐13/14 cover only the dr
Case Syllabus (G.R. No. 195835)
Procedural Posture
- Petition for review on certiorari under Rule 45 assails the Court of Appeals’ Decision dated July 9, 2010 and Resolution dated February 24, 2011 in CA-G.R. SP No. 95471.
- The CA had annulled DOJ Resolutions of March 10 and May 25, 2006, which found no probable cause for copyright infringement and directed withdrawal of information.
- The Supreme Court granted the petition to determine whether the CA rightly concluded that the DOJ committed grave abuse of discretion.
Antecedents and Factual Background
- Petitioners are officers and/or directors of Metrotech Steel Industries, Inc., subcontracted for floors 23–41 of the Manansala Project in Rockwell Center, Makati.
- Respondent Lim Eng Co chairs LEC Steel Manufacturing Corp., which supplied hatch doors for floors 7–22 under SKI-FB’s subcontract.
- LEC submitted shop plans and drawings in July 2002, finalized them January 15, 2004, and obtained SKI-FB’s approval on February 3, 2004.
- Metrotech produced and installed hatch doors using drawings provided by SKI-FB for the upper floors.
Intellectual Property Registration
- July 2, 2004: LEC deposited final shop plans/drawings for hatch doors with the National Library.
- July 6, 2004: Certificates of Copyright Registration Nos. 1-2004-13 and 1-2004-14 issued under Section 172(i) (illustrations, maps, plans, sketches, charts, three-dimensional works).
- December 9, 2004: Certificates H-2004-566 and H-2004-567 issued under Section 172(h) (original ornamental designs or models for articles of manufacture).
Preliminary Investigation and DOJ Resolutions
- August 13, 2004: NBI, upon DOJ application, executed a search warrant at Metrotech, seizing doors and machinery.
- Same date: Respondent filed Complaint-Affidavit before the DOJ for copyright infringement.
- August 18, 2005: Investigating prosecutor dismissed complaint for inadequate evidence on prohibited acts and copyrightability.
- November 16, 2005: DOJ denied respondent’s petition for review.
- January 27, 2006: DOJ reversed the dismissal, found probable cause based on artistic and ornamental features, and directed filing of i