G.R. No. 97343 September 13, 1993
PASCUAL GODINES, petitioner, vs. THE HONORABLE COURT OF APPEALS, SPECIAL FOURTH DIVISION and SV-AGRO ENTERPRISES, INC., respondents.

FACTS

Magdalena S. Villaruz was issued Letters Patent No. UM-2236 for a utility model of a hand tractor or power tiller. The patent was assigned to SV-Agro Enterprises, Inc., which manufactured and sold the patented power tillers. In 1979, SV-Agro suffered a significant sales decline and discovered that petitioner Pascual Godines was manufacturing and selling similar power tillers. Despite a demand to cease, Godines continued, prompting SV-Agro to file a complaint for infringement of patent and unfair competition. The Regional Trial Court found Godines liable, a decision affirmed by the Court of Appeals. Godines petitioned for review, arguing he manufactured only upon special customer orders and that his products were different from SV-Agro’s.

ISSUE

1. Whether petitioner Pascual Godines was engaged in the manufacture and sale of power tillers, constituting infringement of patent.
2. Whether petitioner’s power tillers infringed upon the patented utility model of private respondent.
3. Whether petitioner is liable for unfair competition.

RULING

The Supreme Court DENIED the petition and AFFIRMED the decision of the Court of Appeals.
1. The Court upheld the factual findings of the lower courts that Godines was engaged in the manufacture and sale of power tillers, rejecting his claim of fabrication only upon special order. The Court of Appeals’ findings on this matter are conclusive.
2. The Court found that petitioner’s power tillers infringed upon the patented utility model. Applying the tests of literal infringement and the doctrine of equivalents, the trial court’s observation established that the power tillers were virtually identical in appearance, form, configuration, design, components, and operational principles. The doctrine of equivalents applies as the devices perform substantially the same function in substantially the same way to achieve the same result, making them the same despite minor modifications.
3. The Court also found petitioner liable for unfair competition under Republic Act No. 166 , as amended, for giving his goods the general appearance of the patented goods, likely to deceive the public.
Petitioner’s liability for infringement is pursuant to Section 37 of Republic Act No. 165 , as amended, which grants patentees the exclusive right to make, use, and sell the patented product.