GR 115106; (March, 1996) (Digest)
G.R. No. 115106 March 15, 1996
ROBERTO L. DEL ROSARIO, petitioner, vs. COURT OF APPEALS AND JANITO CORPORATION, respondents.
FACTS
Petitioner Roberto del Rosario, a patentee of utility models for a sing-along system (karaoke), filed a complaint for patent infringement against respondent Janito Corporation. He alleged that Janito was manufacturing and selling the “Miyata” karaoke system, which was substantially similar to his patented models. The Regional Trial Court (RTC) of Makati granted del Rosario’s application for a writ of preliminary injunction, enjoining Janito from using, selling, or advertising the “Miyata” system.
Janito Corporation assailed the RTC order via a petition for certiorari before the Court of Appeals. The appellate court granted the petition and set aside the injunction. It expressed the view that the karaoke system was a universal product manufactured worldwide long before del Rosario’s patents were issued, and that there was no infringement based solely on Janito’s manufacture of a similar audio system.
ISSUE
Whether the Court of Appeals erred in finding that the trial court committed grave abuse of discretion in issuing the writ of preliminary injunction against Janito Corporation for alleged patent infringement.
RULING
Yes. The Supreme Court reversed the Court of Appeals and reinstated the RTC’s writ of preliminary injunction. The legal logic centered on the requisites for issuing a preliminary injunction and the prima facie showing of patent infringement.
A preliminary injunction requires only two requisites: (1) the existence of a right to be protected, and (2) that the acts against which the injunction is sought are violative of that right. The Court found that del Rosario, as a patent holder, possessed a clear legal right to be protected. The critical inquiry was whether he established a prima facie case of violation of that right to justify provisional relief pending the main suit.
The Court held that he did. It scrutinized the comparative features of the two models. While Janito presented differences, it failed to refute the core allegations that both systems performed substantially the same functions (e.g., singing with minus-one tapes, voice enhancement via echo, recording capabilities, and use of microphones) and produced identical results. The modes of operation and end results were essentially the same. This constituted a prima facie showing of infringement, warranting the injunctive relief to prevent continuous irremediable injury to del Rosario’s patent rights during the litigation. The trial court did not commit grave abuse of discretion; it correctly exercised its discretion based on the evidence presented.