G.R. No. 161693; June 28, 2005
MANOLO P. SAMSON, petitioner, vs. HON. VICTORIANO B. CABANOS, In his capacity as Acting Presiding Judge, Regional Trial Court of Antipolo City, Branch 71, PEOPLE OF THE PHILIPPINES and CATERPILLAR, INC., respondents.

FACTS

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, the Intellectual Property Code, before the Regional Trial Court (RTC) of Antipolo City. The Information alleged he distributed and sold footwear and other items using trademarks identical to Caterpillar, Inc.’s registered marks. The prescribed penalty under Section 170 of R.A. No. 8293 is imprisonment from two to five years and a fine ranging from Fifty Thousand to Two Hundred Thousand Pesos.
Petitioner moved to quash the Information, arguing the RTC lacked jurisdiction. He contended that under R.A. No. 7691, which amended the Judiciary Reorganization Act, Metropolitan Trial Courts (MTCs) have exclusive original jurisdiction over offenses punishable by imprisonment not exceeding six years, irrespective of the fine. Since the penalty for unfair competition is only two to five years, he asserted jurisdiction properly lies with the MTC, not the RTC.

ISSUE

Whether the Regional Trial Court has jurisdiction over the criminal case for unfair competition, given that the prescribed penalty is imprisonment of two to five years, which is within the exclusive original jurisdiction of the Metropolitan Trial Courts under R.A. No. 7691.

RULING

The Supreme Court dismissed the petition and upheld the RTC’s jurisdiction. The Court applied the doctrine that a special law prevails over a general law. R.A. No. 8293, the Intellectual Property Code, is a special law which, under its Section 163, provides that actions under its specified sections, including Section 168 on unfair competition, “shall be brought before the proper courts with appropriate jurisdiction under existing laws.”
The Court, referencing its prior ruling in Samson vs. Daway, held that R.A. No. 8293 and the earlier special law, R.A. No. 166 (the old Trademark Law), which both conferred jurisdiction over intellectual property violations to the then Courts of First Instance (now RTCs), must prevail over the general jurisdictional provisions of R.A. No. 7691. Therefore, jurisdiction over criminal cases for unfair competition remains with the RTC, even if the penalty involves imprisonment of less than six years. This interpretation is reinforced by the Supreme Court’s administrative issuances designating specific RTCs as Intellectual Property Courts to handle such specialized cases. The passing remark in Mirpuri vs. Court of Appeals regarding the repeal of R.A. No. 166 was not a jurisdictional pronouncement and does not alter this conclusion. The principle of “law of the case” from Samson vs. Daway controls this identical issue.