GR 160054; (July, 2004) (Digest)
G.R. Nos. 160054-55 July 21, 2004
Manolo P. Samson, petitioner, vs. Hon. Reynaldo B. Daway, in his capacity as Presiding Judge, Regional Trial Court of Quezon City, Branch 90, People of the Philippines and Caterpillar, Inc., respondents.
FACTS
Petitioner Manolo P. Samson, owner of ITTI Shoes, was charged before the Regional Trial Court (RTC) of Quezon City with two counts of unfair competition under the Intellectual Property Code ( R.A. No. 8293 ). The informations alleged he distributed products bearing imitations of Caterpillar, Inc.’s registered trademarks. Petitioner filed a motion to suspend arraignment, citing a pending civil case for unfair competition and a petition for review with the Secretary of Justice assailing the finding of probable cause. The RTC denied this motion.
Subsequently, petitioner filed a motion to quash the informations, challenging the RTC’s jurisdiction. He argued that since the penalty for unfair competition under Section 170 of R.A. No. 8293 is imprisonment not exceeding six years, the offense, pursuant to R.A. No. 7691 , falls within the jurisdiction of the Municipal Trial Courts and not the RTC. The trial court denied both the motion to quash and a motion for reconsideration, prompting this petition for certiorari alleging grave abuse of discretion.
ISSUE
The primary issue is which court has jurisdiction over criminal cases for unfair competition under the Intellectual Property Code.
RULING
The Supreme Court ruled that the Regional Trial Court retains jurisdiction. The legal logic hinges on the interpretation of the interplay between R.A. No. 8293 and the prior trademark law, R.A. No. 166 . Section 170 of R.A. No. 8293 prescribes the penalty for unfair competition. Section 163 of the same Code provides that actions under it, including criminal cases, “shall be brought before the proper courts with appropriate jurisdiction under existing laws.”
The phrase “existing laws” refers to Section 27 of R.A. No. 166 (The Trademark Law), which expressly vested jurisdiction over cases for unfair competition in the Court of First Instance (now the RTC). The Court found that R.A. No. 8293 did not expressly repeal R.A. No. 166 in its entirety. The repealing clause (Section 239) only repeals acts or parts of acts inconsistent with R.A. No. 8293 . Since R.A. No. 8293 is silent on which court has jurisdiction, there is no inconsistency with the jurisdictional provision of R.A. No. 166 . Therefore, the latter’s provision conferring jurisdiction to the RTC remains effective and applicable.
Consequently, the RTC correctly assumed jurisdiction. The petitioner failed to demonstrate that the trial court committed grave abuse of discretion in denying the motions. The petition was dismissed for lack of merit.