G.R. No. 195549 - Willaware Products Corp. vs. Jesichris Manufacturing Corp.

In November 2000 respondent discovered that petitioner had begun manufacturing and selling automotive plastic parts identical in design, material, color, and to the same customers, at lower prices.
Respondent alleged it originated the use of plastic in place of rubber for parts such as spring eye bushings, stabilizer bushings, and shock absorber bushings.
Petitioner denied wrongful acts, asserting its products conformed to original equipment specifications, were mere reproductions, and that no patent or exclusive right barred such manufacture.

The Regional Trial Court (RTC) found petitioner liable for unfair competition under Article 28 of the Civil Code, having copied respondent’s products through the use of respondent’s former employees.
Actual damages of ₱2,000,000, attorney’s fees of ₱100,000, and exemplary damages of ₱100,000 were awarded.
The RTC enjoined petitioner from manufacturing the disputed plastic-made automotive parts.

The Court of Appeals (CA) upheld liability for unfair competition but deleted the award of actual damages due to lack of specific proof, substituting nominal damages of ₱200,000.
The CA maintained the RTC award of attorney’s fees and exemplary damages, and affirmed the permanent injunction.
Petitioner’s motion for reconsideration was denied.

Whether petitioner’s conduct constitutes unfair competition under Article 28 of the Civil Code when no patent or copyright protects the products.
Whether damages, moral damages, and attorney’s fees are proper absent established rights.
Whether nominal damages may be awarded.
Whether respondent’s asserted copyright, previously invalidated, plays any role.
Whether respondent has established goodwill.

Article 28 of the 1987 Philippine Constitution and Article 28 of the Civil Code (on human relations).
Unfair competition under Article 28 covers any “unjust, oppressive or high-handed method” in trade rivalry, including misappropriation of trade secrets, bribery of employees, deceit, or undue interference with a competitor’s business.

The petition is denied.
The CA Decision dated November 24, 2010 and Resolution dated February 10, 2011 are affirmed with modification: attorney’s fees are reduced to ₱50,000.

Trade Rivalry and Unfair Means
- Both parties were competitors in plastic automotive parts.
- Petitioner’s recruitment of respondent’s employees, deliberate copying of product design, and diversion of respondent’s customers constitute “unjust, oppressive or high-handed methods.”
Absence of Intellectual Property Registration
- The absence of patent or copyright registration is immaterial under Article 28’s b