09 MANOLO SAMSON vs JUDGE DAWAY of RTC QC Branch 90, PEOPLE OF THE PHILIPPINES It was noted that RA 8293 did

It was noted that RA 8293 did not entirely repeal RA 166 but only those provisions that are not
AND CATERPILLAR, INC. harmonized with the new RA. SC held that jurisdiction as provided in RA 8293 did not repeal and is very
GR 160054-55 July 21, 2004 much consistent with jurisdiction provided in RA 166 which was conferred to CFI now RTC.
Justice Ynares-Santiago
Besides, since RA 7691 is a general law and IPC in relation to Trademark Law is a special law, the
Nature latter shall prevail pursuant to the settled rule in statutory construction. Actions for unfair competition
Assailed in this petition for certiorari is the March 26, 2003 Order of the RTC of Quezon City, which therefore should be filed with the RTC. Jurisdiction conferred by a special law to Regional Trial Courts
denied petitioners (1) motion to quash the information; and (2) motion for reconsideration of the August must prevail over that granted by a general law to Municipal Trial Courts.
9, 2002 Order denying his motion to suspend the arraignment and other proceedings in Criminal Case
Nos. Q-02-108043-44. Petitioner also questioned its August 5, 2003 Order which denied his motion for Disposition: Petition is DISMISSED (not only because there was failure to establish grave abuse of
reconsideration. discretion but also because there was failure to attach documents relevant to the allegations that
warrants the dismissal of the petition).
Facts
On March 7, 2002, two informations for unfair competition under Section 168.3 (a), in relation to Section
170, of the Intellectual Property Code (Republic Act No. 8293), were filed against petitioner Manolo P.
Samson, the registered owner of ITTI Shoes.

The petitioner, owner/proprietor of ITTI Shoes/Mano Shoes Manufacturing Corporation, allegedly sold
or offers the sale of garment products using the trademark CATERPILLAR products such as footwear,
garments, clothing, bags, accessories and paraphernalia which are closely identical to and/or colorable
imitations of the authentic Caterpillar products and likewise using trademarks, symbols and/or designs
as would cause confusion, mistake or deception on the part of the buying public to the damage and
prejudice of CATERPILLAR, INC, private respondent in this case.

PROCEEDINGS BEFORE THE SUPREME COURT:

RTC: The respondent filed the case with the RTC. Consequently, in an Order dated August 9, 2002,
the trial court denied the motion to suspend arraignment and other proceedings filed by the petitioner.

The petitioner filed a motion to quash by challenging the jurisdiction of the trial court over the offense
charged contending that the case should be filed with the MTC because violation of unfair competition is
penalized with imprisonment not exceeding 6 years under RA 7691. Hence, the instant petition alleging
that respondent Judge gravely abused its discretion in issuing the assailed orders.

Issue/s:
Which court has jurisdiction over criminal and civil cases for violation of intellectual property rights?

Held: RTC has jurisdiction.

Section 170 of the Intellectual Property Code (IPC) provides the penalty for the crime of infringement
which is 2-5 years imprisonment and fine of 50k – 200k. Corollarily, Section 163 of the same code
provides that actions for unfair competition shall be brought before the proper courts with appropriate
jurisdiction under existing laws. The “existing law” contemplated in Section 163 of IPC is RA 166
otherwise known as the Trademark Law.

Sec 27 of the Trademark Law provides that jurisdiction over cases for infringement of registered marks,
unfair competition, false designation of origin and false description or representation, is lodged with the
Court of First Instance (now Regional Trial Court).