G.R. No. 249715 , April 12, 2023
M.Y. INTERCONTINENTAL TRADING CORPORATION, TEDWIN T. UY, AND ALLIANZ MARKETING AND PUBLISHING CORPORATION, PETITIONERS, VS. ST. MARY’S PUBLISHING CORPORATION AND JERRY VICENTE S. CATABIJAN, RESPONDENTS.

FACTS

St. Mary’s Publishing Corporation is the copyright owner of certain textbooks. To fund the printing of its books in China, its President, Jerry Vicente S. Catabijan, entered a business venture with M.Y. Intercontinental Trading Corporation and Tedwin T. Uy. M.Y. Intercontinental acted as the agent for the Chinese printer, Fujian. The parties entered into a financing agreement where St. Mary’s Publishing obtained a loan from the petitioners to cover printing costs. St. Mary’s Publishing later defaulted on its loan obligations. In April 2010, Catabijan allegedly gave a signed Deed of Assignment of all its copyrights to Uy as a prelude to a dacion en pago, which failed to materialize. M.Y. Intercontinental subsequently registered this Deed of Assignment, and copyright registrations for the textbooks were issued in its name in January 2012. Due to St. Mary’s Publishing’s failure to pay, the textbooks subject of a December 7, 2009 purchase order were not delivered. In a prior declaratory relief case, the Regional Trial Court of Mandaluyong declared M.Y. Intercontinental an unpaid seller with a lien on the books and the right to resell them. In 2012, St. Mary’s Publishing discovered that M.Y. Intercontinental had sold the textbooks to the City of Cabuyao and that Allianz Marketing and Publishing Corporation had imported and sold them. St. Mary’s Publishing then filed a complaint for copyright infringement against the petitioners.

ISSUE

Whether the petitioners committed copyright infringement by importing, marketing, and selling the subject textbooks.

RULING

Yes, the petitioners committed copyright infringement. The Supreme Court held that a forged Deed of Assignment does not confer rights to the assignee for lack of consent of the copyright owner. Notwithstanding its registration before the National Library, the Deed does not operate as a valid transfer of the exclusive economic rights which belong to the copyright owner. The Court found that the Deed of Assignment was forged, as Catabijan denied signing it and the notary public testified it was not acknowledged before him. Therefore, M.Y. Intercontinental acquired no copyrights through the Deed. The unauthorized acts of importing, marketing, and selling the books constituted infringement of St. Mary’s Publishing’s exclusive rights. The Court affirmed the findings of the Regional Trial Court and the Court of Appeals that the petitioners were liable for copyright infringement and upheld the award of damages.