G.R. No. 30774 , January 29, 1929
PHILIPPINE EDUCATION COMPANY, INC., plaintiff-appellee, vs. VICENTE SOTTO and V. R. ALINDADA, defendants. V. R. ALINDADA, appellant.

FACTS

The Philippine Education Company, Inc., publisher of the “Philippine Education Magazine,” contracted with Austin Craig for the exclusive right to publish his original article, “The True Story of Mrs. Rizal.” The article was published in the magazine’s December 1927 issue with a notice stating “All Rights Reserved.” However, the article was not registered under the Copyright Act ( Act No. 3134 ). The defendant, V. R. Alindada, as editor of “The Independent,” reproduced and published the article in its December 24 and 31, 1927 issues without permission and, after being notified by the plaintiff, refused to acknowledge any infringement, claiming the article was not copyrighted. The plaintiff sued for damages and an injunction. The trial court ruled in favor of the plaintiff, awarding damages. The defendant appealed, arguing that without copyright registration, no exclusive right existed and the “All Rights Reserved” notice was ineffective.

ISSUE

Whether the publication of an original article in a periodical with the notice “All Rights Reserved,” but without formal copyright registration under Act No. 3134 , confers upon the publisher an exclusive right of reproduction that can be enforced against unauthorized republication.

RULING

NO. The Supreme Court reversed the trial court’s decision and dismissed the complaint.
The Court held that under Act No. 3134 (the Copyright Law), the exclusive right to reproduce a published work is acquired only through compliance with the statutory procedure for copyright registration. The law does not recognize a separate, common-law property right in published works that bypasses the copyright system. The notice “All Rights Reserved” has no legal effect under Philippine law for uncopyrighted matter; it is merely a warning or claim that cannot, by itself, create an exclusive right. Since the plaintiff did not register the article with the Copyright Office, it did not acquire a copyright. Consequently, the defendant’s act of republishing the article did not constitute an infringement of any legally protected right. The Court emphasized that the statutory scheme for copyright is comprehensive and exclusive, and rights are only secured by following its mandates.