Case Summary (G.R. No. 208090)
Background of the Case
The petitioner, Ferdinand V. Tomas, seeks to overturn the decision of the Court of Appeals affirming the finding of probable cause against him for trademark infringement and unfair competition, as defined and penalized under specified sections of the Intellectual Property Code of the Philippines. The private respondent, Myrna Uy Tomas, filed multiple complaints leading to these findings, prompting the CIDG to seek search warrants that would eventually result in the seizure of items associated with the alleged infringements.
Search Warrant Applications
On October 24, 2007, the CIDG submitted applications for search warrants concerning premises associated with the petitioner. These applications were signed by a CIDG officer but notably did not include the personal endorsement of the Chief of the PNP. The subsequent search produced various confiscated items, including water pumps and boxes.
Motion to Quash
The petitioner filed a Motion to Quash concerning the search warrants on the basis that they were not endorsed per the guidelines set out in A.M. No. 03-8-02-SC, which stipulates that applications for such warrants must be personally endorsed by the heads of specific law enforcement agencies. The Regional Trial Court initially granted a partial quashal of the warrants but was later moved to reconsider this decision.
Court of Appeals Rulings and Subsequent Proceedings
The Court of Appeals ultimately reversed the decisions of the RTC, asserting that the absence of personal endorsement by the Chief of the PNP did not render the warrants invalid. The CA's ruling led the petitioner to file an additional petition questioning the Secretary of Justice’s Joint Resolution that found probable cause against him.
Key Legal Issues Raised by the Petitioner
The petitioner raised significant legal issues regarding the immutability principle of final judgments, asserting that the CA’s ruling contradicted its earlier decision where the search warrants were previously deemed invalid. Additionally, the petitioner contended that the CA’s dismissal of his subsequent petition constituted forum shopping, as the same issues had already been resolved.
Findings of the Supreme Court
The Supreme Court, in its decision, emphasized the doctrine of immutability of judgments, which states that once a judgment becomes final, it cannot be altered. It agreed that the eligibility of a search warrant must rest on its adherence to procedural requirements, specifically that search applications need the personal endorsemen
...continue readingCase Syllabus (G.R. No. 208090)
Background of the Case
- The case originates from a Petition for Review on Certiorari filed by Ferdinand V. Tomas, seeking to reverse and set aside decisions made by the Court of Appeals (CA).
- The CA's decisions affirmed a Joint Resolution from the Secretary of Justice which found probable cause against Tomas for trademark infringement and unfair competition as defined under the Intellectual Property Code of the Philippines (R.A. No. 8293).
- Myrna Uy Tomas filed multiple complaints against Ferdinand V. Tomas and others, leading to the issuance of search warrants by the Regional Trial Court (RTC) of Manila.
Complaints and Search Warrants
- The complaints filed by Myrna Tomas were for violations of Sections 155 and 168 of R.A. No. 8293, involving trademark infringement and unfair competition.
- The Philippine National Police (PNP) CIDG-AOCD filed applications for search warrants, which were signed by Chief Inspector Helsin B. Walin and approved by Police Director Edgardo M. Doromal.
- The RTC issued four search warrants, leading to the search of premises associated with FMT Merchandising and subsequent seizures of items related to Pedrollo products.
Motion to Quash and RTC Decisions
- Ferdinand Tomas filed a Motion to Quash the search warrants, claiming they violated Supreme Court Administrative Matter No. 03-8-02-SC, which required personal endorsement by the heads of the filing agencies.
- The RTC partially granted the motion, quashing two of the search warrants but later reconsidered its decision, rein