Case Summary (G.R. No. 148420)
Background of the Case
On April 8, 1997, an information was filed against the petitioners for allegedly violating Article 189 of the Revised Penal Code (RPC) by distributing counterfeit Ray-Ban sunglasses. Bausch & Lomb, Inc., represented by State Prosecutor Zenaida M. Lim, alleged that the petitioners caused public deception by selling these counterfeit goods, thereby harming the brand's reputation.
Procedural History
On January 21, 1998, the respondent moved to transfer the case to Branch 9 of RTC Cebu City, which was designated as a special court to handle intellectual property rights violations under Administrative Order No. 113-95. The petitioners subsequently filed a motion to quash the information, arguing that the RTC lacked jurisdiction, as the penalties associated with the alleged offense fell within the jurisdiction of the Municipal Trial Court in Cities (MTCC).
Trial Court's Decision
The RTC denied the respondent's motion to transfer the case and granted the motion to quash, concluding that the alleged violation pertained to a jurisdictional area limited to the MTCC. The court held that the relevant administrative orders could not override the explicit jurisdiction established by Batas Pambansa Blg. 129.
Appeal and Court of Appeals Ruling
Respondent Bausch & Lomb filed a petition for certiorari in the Court of Appeals, one day late, which raised procedural concerns. Despite the late filing, the appellate court exercised its discretion to allow the petition and ultimately reversed the RTC ruling, transferring the case to Branch 9 of the RTC.
Issues on Review
The petitioners challenged the appellate court's decision on two key grounds: the alleged failure to dismiss a petition fraught with procedural infirmities, and the claim that the RTC lacked jurisdiction to hear the case concerning unfair competition under Article 189 of the RPC.
Supreme Court's Conclusion
The Supreme Court determined there was no merit to the petitioners' claims. While acknowledging procedural lapses by the respondent, it ruled that equitable considerations warranted the acceptance of the certiorari petition. The Court emphasized the importance of substantial justice over procedural technicalities, stating that a petition for certiorari may be considered valid without prior motion for reconsideration under certain conditions, including the patent nullity of a lower court order.
Jurisdictional Authority
Analyzing the jurisdiction of the RTC, the Court referenced Section 5(5) of the 1987 Constitution, which empowers the Supreme Court to establish
...continue readingCase Syllabus (G.R. No. 148420)
Case Background
- This case revolves around a petition for review of the decision and resolution made by the Court of Appeals concerning the transfer of Criminal Case No. CBU-45890.
- The case was initially filed by the State Prosecutor on April 8, 1997, against the petitioners for distributing counterfeit RAY BAN sunglasses, allegedly leading to unfair competition and violation of Article 189 of the Revised Penal Code (RPC).
- The original trial court was Branch 21 of the Regional Trial Court (RTC) in Cebu City, presided over by Judge Genis Balbuena.
Procedural History
- On January 21, 1998, the respondent, Bausch & Lomb, Inc., filed a motion to transfer the case to Branch 9 of the RTC, designated as a special court for intellectual property rights cases.
- The petitioners countered with a motion to quash the information, arguing the RTC lacked jurisdiction as the offense fell under the jurisdiction of the Municipal Trial Court in Cities (MTCC).
- The RTC denied the motion to transfer and granted the motion to quash on December 22, 1998, asserting it lacked jurisdiction over the case.
Court of Appeals Proceedings
- Following the RTC's ruling, the respondent filed a petition for certiorari with the Court of Appeals on March 23, 1999, which was one day late according to the procedural rules.
- Despite the procedural lapse, the appellate court accepted the petition and ultimately reversed the RTC's decision, ordering the transfer of the case