People v. Sasot
REITERATIONFacts
The Antecedents: This case concerns a criminal prosecution against petitioners Melbarose R. Sasot and Allandale R. Sasot for unfair competition under Article 189 of the Revised Penal Code. The National Bureau of Investigation (NBI) initiated an investigation following a complaint by NBA Properties, Inc., a foreign corporation registered as the owner of various NBA trademarks. The NBI's report indicated that the petitioners were engaged in the manufacture, printing, sale, and distribution of counterfeit NBA garment products, leading to a recommendation for their prosecution. Procedural History: Following the NBI's recommendation, an Information was filed before the Regional Trial Court (RTC) of Manila, charging the petitioners with unfair competition. The petitioners filed a Motion to Quash the Information, arguing that the facts did not constitute an offense and that the court lacked jurisdiction. The RTC denied this motion. Subsequently, the petitioners filed a special civil action for certiorari with the Court of Appeals (CA), which was also dismissed. The CA ruled that certiorari was not the proper remedy to assail the denial of a motion to quash and that the grounds raised should be addressed during the trial on the merits. The CA's decision was later upheld upon a motion for reconsideration. The Petition: The petitioners have filed a petition for review on certiorari under Rule 45 of the Rules of Court, raising several issues. These include whether a foreign corporation not licensed to do business in the Philippines can maintain an action for unfair competition, the authority of a corporate officer to act on behalf of the corporation, the entitlement of a foreign corporation to Philippine legal protection for trademarks not in actual use, the RTC's assumption of jurisdiction, and the CA's alleged grave abuse of discretion in dismissing their petition. They reiterate arguments regarding the alleged defectiveness of the complaint, the lack of authority of the complainant's representative, and the non-use of their trademarks in the Philippines.
Issue(s)
Whether a special civil action for certiorari is the proper remedy to assail the denial of a motion to quash. Whether the facts charged constitute an offense for unfair competition under Article 189 of the Revised Penal Code. Whether the trial court had jurisdiction over the offense charged or the person of the accused. Whether a foreign corporation not engaged in business in the Philippines and not a registered patentee is entitled to protection under Philippine law for unfair competition. Whether the Court of Appeals committed grave abuse of discretion amounting to lack of jurisdiction when it dismissed the petition.
Ruling
The petition is denied for lack of merit. The records of the case are remanded to the Regional Trial Court of Manila (Branch 24) for further proceedings.
Ratio Decidendi
On the propriety of certiorari: The Court reiterated its consistent holding that a special civil action for certiorari is not the proper remedy to assail the denial of a motion to quash an information. The proper procedure is to enter a plea, proceed to trial without prejudice to presenting special defenses, and if an adverse decision is rendered, to appeal therefrom. The Court found no special or exceptional circumstances in the present case to justify an immediate resort to certiorari, thus affirming that the CA did not commit grave abuse of discretion in dismissing the petition. On the grounds for quashing the Information and the nature of Unfair Competition as a public crime: The Court found no justification for the quashal of the Information, noting that the grounds raised by petitioners are not among the enumerated grounds for a motion to quash. The Court also found the complaint substantially sufficient. The Court stressed that the crime of Unfair Competition is a public crime, essentially an act against the State, with the latter as the principal injured party. Consequently, the complainant's capacity to sue becomes immaterial. On the trial court's jurisdiction: The Court found the complaint substantially sufficient, noting that the Complaint-Affidavit was sworn to before a notary public and authenticated by the Philippine Consulate, and that other supporting documents like the NBI Report and affidavits were available to the prosecutor. The Court emphasized that want of oath in a complaint is a mere defect of form that does not affect substantial rights. On the protection of foreign trademarks and the capacity to sue: The Court affirmed that foreign corporations, even if not doing business in the Philippines, are entitled to protection under Philippine law for unfair competition and infringement of trademarks, especially when the Philippines is a party to international conventions. The Court also noted that the prosecutor enjoys the presumption of regularity in the performance of duties, and the prosecutor's determination to file an information should be respected in the absence of manifest error, grave abuse of discretion, or prejudice. On petitioners' defenses: The Court held that petitioners' arguments regarding the NBA Properties, Inc. not being entitled to protection under Philippine patent laws, not being a registered patentee, and their own designs being original and dissimilar to the complainant's, are matters of defense that are better ventilated and resolved during the trial on the merits of the case. These were not grounds for quashing the information.
Main Doctrine
A special civil action for certiorari is not the proper remedy to assail the denial of a motion to quash; the accused should proceed to trial and appeal any adverse decision. Furthermore, the capacity to sue of a complainant is immaterial in prosecuting a public crime like unfair competition.