G.R. No. L-22756 March 18, 1966
HONDA GIKEN KOGYO KABUSHIKI KAISHA, ET AL., petitioners, vs. HON. LOURDES P. SAN DIEGO, ET AL., respondents.

FACTS

Petitioner Honda Giken Kogyo Kabushiki Kaisha (Honda) is the manufacturer and trademark owner of Honda motorcycles. Respondent Alfred Hahn had been importing these motorcycles into the Philippines since 1959 under authority from Honda. On December 13, 1962, Hahn filed an application with the Philippine Patent Office to register the trademark “HM HONDA” in his name. Honda opposed this application. During the proceedings before the Patent Office Hearing Officer, Honda presented its evidence. Hahn’s counsel then orally moved to dismiss the opposition, questioning Honda’s personality to appear before the Patent Office on the ground that it was not licensed to do business in the Philippines. The Hearing Officer denied the motion. Hahn filed a motion for reconsideration, which was pending when the Director of Patents issued an order granting Hahn ten days to submit further arguments. Instead of complying, Hahn filed a petition for certiorari (Civil Case No. Q-7864) in the Court of First Instance of Rizal, seeking to annul the Patent Office order denying his motion to dismiss. The respondent judges issued orders and a writ of preliminary injunction restraining the Director of Patents and Hearing Officers from recognizing Honda’s capacity to oppose or proceeding with the merits of the opposition. Honda then filed the present petition for certiorari and prohibition to annul these orders.

ISSUE

Whether the Court of First Instance of Rizal had jurisdiction to issue injunctive relief (a writ of preliminary injunction) against the Philippine Patent Office.

RULING

No. The Supreme Court granted the petition, setting aside the orders of the respondent judges. The Court held that the respondent judges had no jurisdiction to issue the orders complained of. The rule is well-settled that a writ of injunction, prohibition, or certiorari may be issued against a court only by another court superior in rank. Under the law, appeals from orders and decisions of the Director of Patents must be taken to the Supreme Court. The Philippine Patent Office is, at the very least, of the same rank or category as a Court of First Instance. Consequently, no Court of First Instance has jurisdiction to issue a writ of injunction against it. The Supreme Court cited an analogous precedent involving the Public Service Commission, where it was held that in the absence of a specific delegation of jurisdiction, no court other than the Supreme Court possesses jurisdiction to grant injunctive relief against orders of such a commission.