G.R. No. 241034. August 03, 2022.
MANILA HOTEL CORPORATION, PETITIONER, VS. OFFICE OF THE DIRECTOR OF THE BUREAU OF LEGAL AFFAIRS OF THE INTELLECTUAL PROPERTY OFFICE OF THE PHILIPPINES AND LE COMITÉ INTERPROFESSIONEL DU VIN DE CHAMPAGNE, RESPONDENTS.

FACTS

Manila Hotel Corporation (petitioner) applied to register the trademark “CHAMPAGNE ROOM” for its restaurant and beverage services. Le Comité Interprofessionel du Vin de Champagne (CIVC), a French entity protecting the “Champagne” appellation of origin, opposed the application. The IPO Adjudication Officer dismissed the opposition, ruling that “Champagne” had become generic and its use for services unrelated to wine did not mislead the public. CIVC received the adverse decision on February 2, 2018. The Rules provided a 10-day period to appeal, expiring on February 12. On February 9, CIVC filed a Motion for Extension of Time to File Appeal, citing heavy workload and the need for coordination with its foreign office.
The IPO-BLA Director granted CIVC a 10-day extension, finding the reason meritorious in the interest of justice. Petitioner opposed, arguing the Revised Rules and Regulations on Inter Partes Proceedings do not allow extensions for appeals from an Adjudication Officer’s decision. The Director issued an order accepting CIVC’s appeal memorandum. Petitioner filed a Petition for Certiorari with the Court of Appeals, which was dismissed. The CA held that the Director did not gravely abuse his discretion, as procedural rules should be liberally construed to serve substantial justice. Petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the IPO-BLA Director committed grave abuse of discretion in granting CIVC’s Motion for Extension of Time to File Appeal, despite the Revised Inter Partes Rules stating the period for filing an appeal is non-extendible.

RULING

No, the IPO-BLA Director did not commit grave abuse of discretion. The Supreme Court affirmed the CA’s ruling. The legal logic rests on the principle that rules of procedure are tools to facilitate, not frustrate, the attainment of justice. While Section 2(a), Rule 9 of the Revised Inter Partes Rules states the adverse party may file a comment within a “non-extendible period,” it is silent on whether the initial period to file the appeal itself can be extended. This silence creates an ambiguity. In such cases, the rules must be interpreted liberally to afford parties a full opportunity to plead their case, especially when no substantial prejudice is shown and the reasons for the delay are meritorious.
The Court emphasized that the Intellectual Property Code (RA 8293) and its implementing rules aim to provide an accessible and swift adjudication system. However, strict technicalities should not be used to deny a party, particularly a foreign entity requiring coordination time, the right to appeal. The Director’s exercise of discretion to grant a single, short extension to prevent a miscarriage of justice was reasonable. Grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. The Director’s act, aimed at allowing a complete resolution of the substantive trademark dispute on its merits, did not meet this high threshold. The procedural lapse, if any, was not so egregious as to warrant nullification through certiorari.