Title
Samson vs. Cabanos
Case
G.R. No. 161693
Decision Date
Jun 28, 2005
Petitioner challenged RTC jurisdiction over unfair competition under R.A. No. 8293, arguing MTC jurisdiction due to penalty. SC upheld RTC jurisdiction, ruling special laws prevail over general laws.
unfair competition
penalty
imprisonment
A

Case Summary (G.R. No. 161693)

Factual Background and the Information for Unfair Competition

Petitioner was the owner or proprietor of ITTI Shoes Corporation, located at F.P. Felix Avenue, Cainta, Rizal. The Information alleged that, in the first week of November 1999 and sometime before or after, within the jurisdiction of the RTC, petitioner willfully, unlawfully and feloniously distributed, sold and/or offered for sale CATERPILLAR products—footwear, garments, clothing, bags, accessories and paraphernalia—which were allegedly closely identical to and/or colorable imitations of authentic Caterpillar products. It likewise alleged that petitioner used trademarks, symbols and/or designs capable of causing confusion, mistake or deception on the buying public, to the damage and prejudice of Caterpillar, Inc., as the prior adopter, user and owner of marks including “CATERPILLAR,” “CAT,” “CATERPILLAR & DESIGN,” “CAT AND DESIGN,” “WALKING MACHINES,” and “TRACK-TYPE TRACTOR & DESIGN.”

Motion to Quash and Denial by the RTC

Petitioner filed a motion to quash the Information, asserting that the RTC lacked jurisdiction. He argued that Sec. 170 of R.A. No. 8293 provides a penalty of imprisonment from two (2) to five (5) years and a fine of P50,000.00 to P200,000.00, and that R.A. No. 7691, amending B.P. Blg. 129, vested in the MTC exclusive original jurisdiction over offenses punishable by imprisonment not exceeding six (6) years, irrespective of the fine.

Presiding Judge Felix S. Caballes denied the motion in an order dated January 22, 2003. Petitioner moved for reconsideration, but Acting Presiding Judge Victoriano B. Cabanos denied that motion in an order dated November 17, 2003.

Petition for Certiorari Before the Supreme Court

Petitioner elevated the matter to the Supreme Court on a pure question of law, namely: whether the RTC had jurisdiction over offenses charged for unfair competition where the penalty range, as provided in Sec. 170 of R.A. No. 8293, was allegedly within the six-year limit under the jurisdictional expansion created by R.A. No. 7691, in relation to Sec. 163 of R.A. No. 8293.

In addition to seeking reversal of the RTC orders, petitioner also prayed for a temporary restraining order and/or preliminary injunction to enjoin further proceedings in Criminal Case No. 02-23183 pending resolution. The Supreme Court issued a temporary restraining order on February 18, 2004.

Petitioner's Arguments on Jurisdiction and Alleged Repeal of the Old Trademark Law

Before the Supreme Court, petitioner reiterated that Sec. 170 fixes the penalty for Sec. 168 violations at imprisonment of two (2) to five (5) years, placing the case within the MTC’s exclusive original jurisdiction under R.A. No. 7691. He also argued that the former Trademark Law, R.A. No. 166, which had conferred jurisdiction on the then Court of First Instance (now RTC) for unfair competition, had been repealed by R.A. No. 8293. In support, he invoked Mirpuri v. Court of Appeals.

The Supreme Court’s Treatment of the Prior Case: Samson v. Daway

The Court dismissed the petition, reasoning that petitioner had already raised the same jurisdictional issues in Samson v. Daway, decided on July 21, 2004. The Court described Samson v. Daway as involving the same facts and issue, differing only in that the Information for unfair competition had been filed before the RTC of Quezon City rather than the RTC of Antipolo City.

The Court then restated the governing framework discussed in Samson v. Daway. It emphasized that under Sec. 170 of R.A. No. 8293—which took effect on January 1, 1998—the criminal penalty for infringement of registered marks, unfair competition, false designation of origin, and false description or representation was imprisonment of two (2) to five (5) years and a fine of P50,000.00 to P200,000.00. It further noted that Sec. 163 of the same Code directs that actions, including criminal and civil actions under Secs. 150, 155, 164, 166, 167, 168, and 169, must be brought before the proper courts with appropriate jurisdiction under existing laws.

According to the Court’s restatement, the “existing law” referred to by Sec. 163 was Sec. 27 of R.A. No. 166, which lodged jurisdiction over cases for infringement, unfair competition, false designation of origin, and false description or representation with the Court of First Instance (now the RTC). The Court found no merit in the claim that R.A. No. 166 was expressly repealed in its entirety by R.A. No. 8293. It relied on the text of the repeal clause, Sec. 239, which repealed acts and parts of acts inconsistent with R.A. No. 8293, and specifically referred to the repealing of “parts of Acts” rather than the whole law.

Reconciling R.A. No. 8293, R.A. No. 166, and R.A. No. 7691: Special Law Over General Law

The Court in Samson v. Daway treated R.A. No. 8293 and R.A. No. 166 as harmonizable where Sec. 27 of R.A. No. 166 aligned with Sec. 163 of R.A. No. 8293. It observed that if R.A. No. 8293 intended to vest intellectual property violations with MTC jurisdiction, it would have expressly provided so under Sec. 163.

The Court also applied the statutory construction principle that, in case of conflict between a general law and a special law, the special law prevails. On that basis, it characterized R.A. No. 8293 and R.A. No. 166 as special laws conferring jurisdiction over violations of intellectual property rights to the RTC, and held that this special jurisdiction prevails over R.A. No. 7691, which the Court treated as a general law that expanded MTC jurisdiction.

Thus, the Court held that jurisdiction over the criminal case for unfair competition properly lay with the RTC, even if the imprisonment term was less than six years—specifically within the range of two (2) to five (5) years and the fine range stated in Sec. 170.

The Court further invoked subsequent institutional measures for specialized handling of such cases. It pointed to A.M. No. 02-1-11-SC issued on February 19, 2002, which designated certain RTCs as Intellectual Property Courts, and to a Resolution dated June 17, 2003 consolidating jurisdiction over Intellectual Property Code and Securities and Exchange Commission cases in designated Special Commercial Courts.

Treatment of Mirpuri v. Court of Appeals

The Court also ruled that Mirpuri v. Court of Appeals—invoked by petitioner—did not control. It explained that nowhere in Mirpuri was there an express statement that Sec. 27 of R.A. No. 166 was repealed by R.A. No. 8293, and it did not make a categorical ruling that jurisdiction over violations of intellectual property rights belonged to the MTC. The Court characterized any remark regarding repeal in Mirpuri as a backgrounder to the enactment of the Intellectual Property Code rather than a jurisdictional pronouncement.

Law of the Case and Final Disposition

The Court treated Samson v. Daway as having settled the jurisdictional question between petitioner and the State in substantially the same factual setting. It invoked the legal principle that whatever is once irrevocably established as the controlling legal rule or decision between the same parties continues to be the law of the case, so long as the facts remain the same. Since the material facts and issue were substantially the same, the Court found no reason to depart from the prior ruling.

Accordingly, the Court dismissed the petition. It also lifted the temporary restraining order issued on February 18, 2004.

Doctrinal Takeaway

The decision affirmed that for criminal prosecutions for unfair c

...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.

About Privacy Terms