Samson v. Cabanos
REITERATIONFacts
The Antecedents: Petitioner Manolo P. Samson was charged with unfair competition under Section 168.3(a) in relation to Sections 123.1(e), 131.3, and 170 of Republic Act (R.A.) No. 8293, otherwise known as the Intellectual Property Code of the Philippines. The Information alleged that Samson, owner of ITTI Shoes Corporation, distributed and sold footwear, garments, and accessories that were closely identical or colorable imitations of authentic Caterpillar products, using trademarks that caused confusion to the buying public, to the prejudice of Caterpillar, Inc. Procedural History: Petitioner filed a motion to quash the information, arguing that the Regional Trial Court (RTC) lacked jurisdiction because Section 170 of R.A. No. 8293 provides a penalty of imprisonment from two (2) to five (5) years, and Section 2 of R.A. No. 7691 (amending Batas Pambansa Blg. 129) vests exclusive original jurisdiction over offenses punishable by imprisonment not exceeding six (6) years in the Metropolitan Trial Courts (MTC). The RTC, through Presiding Judge Felix S. Caballes and later Acting Presiding Judge Victoriano B. Cabanos, denied the motion to quash. Petitioner then filed a petition for certiorari before the Supreme Court. The Petition: Petitioner reiterated his argument that the MTC, not the RTC, has jurisdiction over the offense charged, citing Section 170 of R.A. No. 8293 and Section 2 of R.A. No. 7691. He also contended that the old Trademark Law, R.A. No. 166, which conferred jurisdiction on the RTC, was repealed by Section 239 of R.A. No. 8293.
Issue(s)
Whether the Regional Trial Court has jurisdiction over the offense of unfair competition under R.A. No. 8293, considering the penalty prescribed and the provisions of R.A. No. 7691. Whether Section 27 of R.A. No. 166 was repealed by R.A. No. 8293.
Ruling
The petition is dismissed. The temporary restraining order issued by the Supreme Court is lifted.
Ratio Decidendi
On the jurisdiction of the Regional Trial Court over unfair competition cases: The Supreme Court held that the Regional Trial Court (RTC) has jurisdiction over the criminal case for unfair competition. The Court clarified that Section 170 of R.A. No. 8293 provides for a penalty of imprisonment from two (2) to five (5) years and a fine. While Section 2 of R.A. No. 7691 grants Metropolitan Trial Courts (MTCs) exclusive original jurisdiction over offenses punishable by imprisonment not exceeding six (6) years, this general rule is superseded by special laws conferring jurisdiction to the RTC. The Court emphasized that Section 163 of R.A. No. 8293 states that actions under its provisions shall be brought before the "proper courts with appropriate jurisdiction under existing laws." The "existing law" referred to is Section 27 of R.A. No. 166 (The Trademark Law), which explicitly lodges jurisdiction over unfair competition cases with the Court of First Instance (now RTC). The Court reasoned that R.A. No. 8293 and R.A. No. 166 are special laws conferring jurisdiction to the RTC, and they should prevail over the general law, R.A. No. 7691. Therefore, the jurisdiction properly lies with the RTC, even if the penalty is less than six years imprisonment. On the repeal of Section 27 of R.A. No. 166: The Supreme Court found no merit in the petitioner's claim that Section 27 of R.A. No. 166 was expressly repealed by R.A. No. 8293. The Court examined the repealing clause of R.A. No. 8293, Section 239, which states that "All Acts and parts of Acts inconsistent herewith... more particularly Republic Act No. 166, as amended... are hereby repealed." The Court noted that the use of "parts of Acts" and "inconsistent herewith" indicates that only provisions repugnant to or not susceptible of harmonization with R.A. No. 8293 were repealed. Section 27 of R.A. No. 166, which confers jurisdiction to the RTC, is consistent and in harmony with Section 163 of R.A. No. 8293. The Court further reasoned that had R.A. No. 8293 intended to vest jurisdiction over intellectual property rights violations with the MTCs, it would have expressly stated so in Section 163. The Court also reiterated the settled rule that in case of conflict between a general law and a special law, the special law prevails. Thus, Section 27 of R.A. No. 166 remains effective and consistent with R.A. No. 8293.
Main Doctrine
The Regional Trial Court retains jurisdiction over criminal cases for unfair competition under Section 168 of R.A. No. 8293, as Section 27 of R.A. No. 166, which confers jurisdiction to the Regional Trial Court, is not inconsistent with R.A. No. 8293 and prevails over the general law (R.A. No. 7691) granting jurisdiction to Metropolitan Trial Courts for offenses punishable by imprisonment not exceeding six years.