G.R. No. L-32160. January 30, 1982.
DOMICIANO A. AGUAS, petitioner, vs. CONRADO G. DE LEON and COURT OF APPEALS, respondents.

FACTS

Conrado G. de Leon, the respondent, held Patent No. 658 for improvements in the process of making mosaic pre-cast tiles. He filed a complaint for infringement against Domiciano A. Aguas and F.H. Aquino and Sons, alleging that Aguas was manufacturing and selling tiles embodying his patented invention despite receiving notice to desist. De Leon sought injunctive relief, damages, and attorney’s fees. Aguas defended by asserting that the patent was invalid, arguing the process was neither new nor inventive as it had been used by other tile makers locally and abroad prior to de Leon’s application. He also claimed his own products were different and that he held separate design patents.
The trial court ruled in favor of de Leon, declaring his patent valid and infringed, granting a perpetual injunction, awarding actual, moral, and exemplary damages, plus attorney’s fees. The Court of Appeals affirmed the trial court’s decision but reduced the award of moral damages from P50,000 to P3,000. Aguas elevated the case to the Supreme Court via a petition for certiorari, challenging the patent’s validity and the finding of infringement.

ISSUE

The core issue is whether the Court of Appeals erred in affirming the trial court’s judgment that upheld the validity of de Leon’s patent and found Aguas liable for infringement.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. On the validity of the patent, the Court held that a patent, once issued by the Patent Office, enjoys a presumption of validity. The burden of proof to overcome this presumption rests on the party challenging it. Aguas failed to present clear and convincing evidence to substantiate his claim that the process was already publicly known or used prior to de Leon’s invention. Mere allegations and general statements about pre-existing use by other manufacturers, without specific, corroborative proof, are insufficient to nullify the patent grant.
Regarding infringement, the Court found that Aguas’s process for making tiles was substantially identical to the patented process of de Leon. The fact that Aguas held separate design patents for the ornamental appearance of tiles was irrelevant, as the suit concerned the infringement of a utility patent for a manufacturing process, not a design patent. The similarity in the functional process constituted infringement. The reduction of moral damages by the Court of Appeals was deemed proper and was not disturbed, as the assessment of such damages is primarily within the appellate court’s discretion. The Court found no reversible error in the appellate court’s factual findings and legal conclusions.