Puma Sportschuhfabriken Rudolf Dassler v. Madayag
REITERATIONFacts
The Antecedents: Puma Sportschuhfabriken Rudolf Dassler K.G. (Puma), a West German corporation, filed two inter partes cases with the Philippine Patent Office (now Bureau of Patents, Trademarks, and Technology Transfers) opposing the registration of Mil-Oro Manufacturing Corporation's (Mil-Oro) trademarks "Puma and Device" and "Puma Label" for sports socks and belts. Puma later filed an Infringement Case with the Regional Trial Court (RTC) of Makati. Mil-Oro's motion to dismiss the infringement case was initially denied, and Puma's application for a preliminary injunction was granted. The Court of Appeals (CA) reversed the RTC and directed the dismissal of the infringement case. Meanwhile, the Bureau of Patents decided the inter partes cases in favor of Mil-Oro, declaring it the prior and actual adopter and user. The CA affirmed this decision. Puma appealed both the infringement case (G.R. No. 75067) and the inter partes cases (G.R. Nos. 75562-63) to the Supreme Court. Procedural History: The Supreme Court, in G.R. No. 75067, initially decided the infringement case in favor of Puma, remanding it to the RTC. However, in G.R. Nos. 75562-63, the Supreme Court, through its Second Division, decided the inter partes cases in favor of Mil-Oro, affirming the CA and the Bureau of Patents' decision. Puma's appeal to the CA in the inter partes cases was found to be late and deficient. Puma's motion for reconsideration in the inter partes cases brought the decision in G.R. No. 75067 to the Court's attention. The Court denied the motion for reconsideration in G.R. Nos. 75562-63 with finality, noting that the decision in the inter partes cases had become final due to Puma's failure to file a timely and correct appeal. Subsequently, the RTC, to which the infringement case had been remanded, dismissed the infringement case on June 23, 1989, considering Mil-Oro's motion to dismiss. Puma filed the instant petition (G.R. No. 90827) to set aside this dismissal order. The Petition: Puma filed the present petition seeking to set aside the RTC's June 23, 1989 order dismissing the infringement case. Puma also filed a separate petition (G.R. No. 85297) to compel the RTC to issue a writ of injunction, which was dismissed by the Supreme Court.
Issue(s)
Whether the RTC committed reversible error in dismissing the infringement case based on res judicata. Whether the doctrine of res judicata applies to the present case, specifically regarding the Bureau of Patents' determination of trademark ownership. Whether Puma's petition was filed late, and the implications of framing the petition as one for review while alleging grave abuse of discretion.
Ruling
The Supreme Court Resolved to DENY the petition for failure of the petitioner to show any reversible error in the questioned decision of the respondent court and for apparent late filing.
Ratio Decidendi
On the RTC's dismissal of the infringement case: The Supreme Court found no reversible error in the RTC's dismissal of the infringement case. The Court noted that the same issue of trademark ownership for belts and sports socks had been extensively litigated in the Bureau of Patents and subsequently affirmed by the Supreme Court in the inter partes cases. The RTC correctly recognized that the Bureau of Patents, as a quasi-judicial body with jurisdiction over the subject matter and parties, had rendered a judgment on the merits. This prior adversary action involved the identity of parties, subject matter, and causes of action, thus making the doctrine of res judicata operative. On the application of res judicata: The Supreme Court affirmed the applicability of the doctrine of res judicata. It emphasized that the determination by the Bureau of Patents, affirmed by the Supreme Court, definitively disposed of the issue of ownership of the trademark "PUMA & DEVICE" for sports socks and belts. The Court cited the principle that the finality of judgments extends not only to courts but also to executive agencies performing quasi-judicial functions. The respondent court, being an inferior court, was bound to respect and follow this declaration. On the timeliness of the petition: The Supreme Court noted that the petition appeared to have been filed late. Puma received the RTC's dismissal order on July 4, 1989, filed a motion for reconsideration on July 18, 1989, received the denial of the motion on October 16, 1989, and filed the petition for review on November 16, 1989, which was seventeen (17) days late. The Court also questioned the nature of the petition, which was entitled as a petition for review but claimed grave abuse of discretion, suggesting it might be an attempt to circumvent the rules for a late petition for review by framing it as a petition for certiorari.
Main Doctrine
The doctrine of res judicata applies not only to courts but also to executive agencies performing quasi-judicial functions, and a final judgment on the merits by such an agency disposes of the issue of ownership of a trademark.