GR 164605; (October, 2006) (Digest)
G.R. No. 164605 ; October 27, 2006
CATERPILLAR, INC., petitioner, vs. MANOLO P. SAMSON, respondent.
FACTS
Petitioner Caterpillar, Inc., a foreign corporation, requested police action against respondent Manolo P. Samson for alleged unfair competition under the Intellectual Property Code. The Regional Trial Court (RTC) issued five search warrants, leading to the seizure of various merchandise bearing Caterpillar’s trademarks from respondent’s establishments. Respondent filed a motion to quash the search warrants. While this was pending, criminal complaints were filed with the Department of Justice (DOJ).
The RTC denied the motion to quash but ordered the immediate release of the seized items to the respondent. The court reasoned that no criminal action had yet been commenced in court and required an undertaking from respondent to produce the items if later required. The Court of Appeals upheld the RTC’s order, noting the trial court’s discretionary power and the dismissal of the DOJ complaints. Caterpillar elevated the case to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in upholding the RTC’s order for the release of the seized items despite the absence of a filed criminal case and the subsequent dismissal of the DOJ complaints.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. The legal logic proceeds from the finality of the administrative proceedings and the nature of the seized items. During the pendency of the Supreme Court review, the DOJ’s dismissal of the criminal complaints against respondent became final, as petitioner failed to appeal the resolution to the Secretary of Justice as required by procedural rules. Consequently, no criminal case would materialize from the search warrants.
Since no criminal or civil case was pending, the return of the seized articles was proper. The Court further addressed petitioner’s claim that the items were crucial evidence. It ruled that for unfair competition, the evidentiary value lies in the simulation of labels and packaging likely to deceive the public, not in the bulk seizure of the goods themselves. The thousands of clothing and footwear items had little evidentiary value for proving the crime. The respondent’s undertaking to produce the items if ordered sufficiently protected any future prosecutorial interest, rendering their continued state custody unnecessary. The RTC did not act arbitrarily in ordering their release.