G.R. No. 134217 - Savage vs. Taypin

Petitioners contended that the Regional Trial Court (RTC) lacked jurisdiction over the unfair competition case, as it was not designated as a special court for Intellectual Property Rights (IPR).
They cited Supreme Court Administrative Order No. 113-95, which designates specific courts to "try and decide" IPR cases.
The Supreme Court clarified that this administrative order does not confer exclusive jurisdiction for all matters, including the issuance of search warrants, to any one court.
Jurisdiction is determined by substantive law, specifically BP Blg. 129, rather than procedural rules or administrative orders.
The authority to issue search warrants for IPR violations is not exclusively assigned to the courts listed in the administrative order.

Petitioners argued that the search warrant application should have been dismissed due to the absence of a certification of non-forum shopping.
They referenced the case of Washington Distillers, Inc. v. Court of Appeals, where a search warrant was quashed due to forum shopping.
The Supreme Court distinguished this case, noting that there was no allegation of forum shopping, only a lack of certification.
The amended Rules of Court require such certification only for initiatory pleadings, not for applications for search warrants.
The absence of a certification does not warrant the dismissal of a search warrant application.

The Court addressed whether unfair competition involving design patents, as punishable under Article 189 of the Revised Penal Code, existed in this case.
The IPR Code, effective January 1, 1998, repealed Articles 188 and 189 of the Revised Penal Code, rendering discussions about these articles moot.
The repealing clause of the IPR Code explicitly nullifies any inconsistent acts, including the aforementioned articles.
Therefore, the issue of unfair competition as a felony has become academic due to the repeal.

The Court examined whether the alleged acts constituted unfair competition under the IPR Code.
The specific acts involved the manufacture of wrought iron furniture similar to that patented by Mendco, without a license.
The IPR Code defines unfair competition but does not explicitly mention design patents as a crime.
The ambiguity in the law necessitates a strict construction against the State and a liberal interpretation in favor of the accused.
The Court concluded that the alleged acts could be classified as patent infringement rather than unfair competition.

Although the case originated in 1997, prior to the enactment of the IPR Code, the Court applied the provisions of the Code.
Article 22 of the Revised Penal Code allows for the retrospective application o...continue reading