In Manolo P. Samson vs. Hon. Victoriano B. Cabanos, the Supreme Court reiterated that Regional Trial Courts (RTCs), not Metropolitan Trial Courts (MTCs), have jurisdiction over criminal cases involving unfair competition under the Intellectual Property Code, despite the penalty falling within the MTC’s general jurisdictional limits. This ruling clarifies that special laws governing intellectual property rights take precedence over general laws defining court jurisdictions. The decision reinforces the RTC’s role in protecting intellectual property rights, ensuring consistent application of the law in unfair competition cases.

Clash of Jurisdictions: Defending Intellectual Property Rights in Unfair Competition Cases

The case of Manolo P. Samson vs. Hon. Victoriano B. Cabanos arose from an information filed against Petitioner Manolo P. Samson for unfair competition before the Regional Trial Court (RTC) of Antipolo City. The information alleged that Samson was distributing, selling, and offering for sale Caterpillar products that were closely identical or colorable imitations of authentic Caterpillar products. Samson moved to quash the information, arguing that the RTC lacked jurisdiction over the offense. He contended that under Republic Act (R.A.) No. 7691, amending Batas Pambansa (B.P.) Blg. 129, the Metropolitan Trial Courts (MTC) have exclusive original jurisdiction over offenses punishable by imprisonment not exceeding six years, irrespective of the fine amount.

Samson’s argument hinged on the penalty for unfair competition under Section 170 of R.A. No. 8293, the Intellectual Property Code, which prescribes imprisonment from two to five years and a fine ranging from fifty thousand to two hundred thousand pesos. The RTC denied the motion to quash, leading Samson to file a petition for certiorari before the Supreme Court, questioning whether the RTC had jurisdiction over the offense given the MTC’s jurisdiction over offenses with imprisonment not exceeding six years.

The Supreme Court dismissed the petition, relying on its previous decision in Samson vs. Daway, which involved similar facts and issues. The Court emphasized that while Section 170 of R.A. No. 8293 provides the penalties for unfair competition, Section 163 of the same Code specifies that actions under Sections 150, 155, 164, and 166 to 169 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 vests jurisdiction over cases for infringement of registered marks, unfair competition, false designation of origin, and false description or representation with the Court of First Instance (now Regional Trial Court).

The Court clarified that R.A. No. 8293 did not expressly repeal R.A. No. 166 in its entirety. The repealing clause of R.A. No. 8293 states that “all Acts and parts of Acts inconsistent herewith” are repealed, indicating that only provisions repugnant or not susceptible of harmonization with R.A. No. 8293 are repealed. Section 27 of R.A. No. 166 is consistent with Section 163 of R.A. No. 8293, indicating no intention to vest jurisdiction over violations of intellectual property rights with the Metropolitan Trial Courts.

Building on this principle, the Supreme Court invoked the rule that in case of conflict between a general law and a special law, the latter prevails. R.A. No. 8293 and R.A. No. 166 are special laws conferring jurisdiction over violations of intellectual property rights to the Regional Trial Court, while R.A. No. 7691 is a general law. Therefore, jurisdiction over criminal cases for unfair competition is properly lodged with the Regional Trial Court, even if the penalty is imprisonment of less than six years. This ensures that the special nature of intellectual property rights is recognized and protected by courts with specific expertise.

To further support this interpretation, the Court noted the implementation of A.M. No. 02-1-11-SC, which designated certain Regional Trial Courts as Intellectual Property Courts to ensure the speedy disposition of cases involving violations of intellectual property rights under R.A. No. 8293. This administrative measure underscores the judiciary’s commitment to addressing intellectual property disputes efficiently and effectively.

Moreover, the Supreme Court addressed the petitioner’s reliance on Mirpuri v. Court of Appeals, clarifying that the case did not explicitly state that Section 27 of R.A. No. 166 was repealed by R.A. No. 8293. The Court emphasized that the passing remark in Mirpuri regarding the repeal of R.A. No. 166 was merely a backgrounder to the enactment of the present Intellectual Property Code and could not be construed as a jurisdictional pronouncement in cases for violation of intellectual property rights.

The Court concluded that its prior ruling in Samson vs. Daway, which addressed the same issue, constituted the law of the case, precluding any deviation from that established legal principle. This doctrine provides that once a legal rule or decision is irrevocably established between the same parties in a case, it continues to be the law of the case, regardless of whether it is correct on general principles, as long as the underlying facts remain the same. Therefore, the petition was dismissed, and the temporary restraining order previously issued was lifted.

FAQs

What was the key issue in this case?	The central issue was determining whether the Regional Trial Court (RTC) or the Metropolitan Trial Court (MTC) had jurisdiction over a criminal case for unfair competition under the Intellectual Property Code, given the penalty prescribed.
What did the petitioner argue?	The petitioner argued that the MTC had jurisdiction because the penalty for unfair competition, imprisonment from two to five years, fell within the MTC’s jurisdictional limit for offenses punishable by imprisonment not exceeding six years.
What was the Court’s ruling?	The Supreme Court ruled that the RTC had jurisdiction, emphasizing that special laws governing intellectual property rights take precedence over general laws defining court jurisdiction. This means that the specific provisions of the Intellectual Property Code and related laws confer jurisdiction to the RTC.
Why did the Court rely on its previous decision in Samson vs. Daway?	The Court relied on Samson vs. Daway because it involved the same issue and parties, establishing the law of the case. The doctrine of the law of the case prevents relitigation of issues already decided in a prior appeal involving the same parties and facts.
What is the significance of R.A. No. 166 (The Trademark Law) in this case?	R.A. No. 166 is significant because it vests jurisdiction over cases of unfair competition with the Court of First Instance (now the RTC). The Court held that R.A. No. 8293 did not expressly repeal this provision, and thus, it remains in effect.
What is the difference between a general law and a special law in this context?	A general law applies broadly to a variety of subjects, while a special law applies to a specific subject or class of subjects. In this case, R.A. No. 7691 is a general law defining the jurisdiction of MTCs, whereas R.A. No. 8293 and R.A. No. 166 are special laws concerning intellectual property rights.
How does this ruling affect intellectual property rights holders?	This ruling reinforces the protection of intellectual property rights by ensuring that cases of unfair competition are heard in the RTC, which has specialized knowledge and experience in handling such disputes. It provides a consistent and reliable forum for addressing violations of intellectual property laws.
What was the effect of the temporary restraining order in this case?	The temporary restraining order (TRO) initially prevented the RTC from proceeding with the criminal case against the petitioner. However, with the dismissal of the petition, the TRO was lifted, allowing the RTC to resume the proceedings.

The Supreme Court’s decision in Manolo P. Samson vs. Hon. Victoriano B. Cabanos reaffirms the jurisdictional boundaries between the RTC and MTC in cases involving violations of intellectual property rights, specifically unfair competition. By prioritizing special laws over general laws, the Court ensures that intellectual property rights are consistently and effectively protected, reinforcing the RTC’s role as the primary forum for resolving such disputes. The ruling provides clarity and stability for businesses and individuals seeking to enforce their intellectual property rights in the Philippines.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MANOLO P. SAMSON, PETITIONER, VS. HON. VICTORIANO B. CABANOS, G.R. No. 161693, June 28, 2005