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Caterpillar Inc v. Samson

1) Caterpillar filed a case against Samson for violations of unfair competition law. Search warrants were issued and merchandise bearing Caterpillar's trademarks were seized from Samson's stores. 2) Samson filed a motion to quash the search warrants, which was denied. However, the court ordered the release of the seized items since no criminal case was filed. 3) The Court of Appeals upheld the release, as no criminal case for unfair competition was filed against Samson. Additionally, Samson admitted owning the seized items, so they had little evidentiary value since their existence was not disputed.

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Nikki Carandang
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737 views2 pages

Caterpillar Inc v. Samson

1) Caterpillar filed a case against Samson for violations of unfair competition law. Search warrants were issued and merchandise bearing Caterpillar's trademarks were seized from Samson's stores. 2) Samson filed a motion to quash the search warrants, which was denied. However, the court ordered the release of the seized items since no criminal case was filed. 3) The Court of Appeals upheld the release, as no criminal case for unfair competition was filed against Samson. Additionally, Samson admitted owning the seized items, so they had little evidentiary value since their existence was not disputed.

Uploaded by

Nikki Carandang
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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CATERPILLAR INC. V. SAMSON Facts Petitioner Caterpillar, Inc.

is a foreign corporation engaged in the business of manufacturing shoes, clothing items, among others. Search warrant applications were filed against Manolo Samson (herein after referred to as Samson) for violations of unfair competition provided under Section 168.3(a) in relation to Sections 131.3, 123(e) and 170 of Republic Act No. 8293, otherwise known as the Intellectual Property Code. Search warrants were then issued against respondent Samson and his other business establishments (Itti Shoes Corporation, Kolms Manufacturing, and Caterpillar Boutique and General Merchandise). Pursuant to the search warrants various merchandise garments, footwear, bags, wallets, deodorant sprays, shoe cleaners and accessories, all bearing the trademarks "CAT," "CAT AND DESIGN," "CATERPILLAR," "CATERPILLAR AND DESIGN," "WALKING MACHINES" and/or "Track-type Tractor and Design" were seized. Respondent Samson filed a motion to quash the search warrants but was denied. However, the Court ordered the release of the articles that were seized since there was no criminal action filed against the respondent. Petitioner then filed Motion for Partial Reconsideration but was denied by the TC. CA also denied the petition after noting that all the criminal complaints that were filed against the respondent were dismissed by the investigating prosecutor and that the respondent never denied the existence of the said items. Issue/s 1) W/N CA erred in upholding the immediate release of the seized items on the ground that there was no criminal action for unfair competition filed against the respondent? 2) W/N the CA erred in ruling that the subsequent dismissal of the investigating State Prosecutor of the criminal complaints against respondent justifies the return of the seized items? Held/Ratio 1) NO. The Joint Resolution of the DOJ has become final; therefore no criminal case was filed against the respondent in relation with the five search warrants that were issued by the Trial Court. There was also no criminal case filed against the articles that were seized. With these, the seized articles should be immediately released. Also, the numerous articles of clothing, footwear and accessories, among others, that were seized had little, if any, evidentiary value for the criminal action of unfair competition. An action for unfair competition is based on the proposition that no dealer in merchandise should be allowed to dress his goods in simulation of the goods of another dealer, so that purchasers desiring to buy the goods of the latter would be induced to buy the goods of the former. The most usual devices employed in committing this crime are the simulation of labels and the reproduction of form, color and general appearance of the package used by the pioneer manufacturer or dealer. In the case at hand the respondent already admitted the existence of the seized articles. The Court therefore ruled that the admissions of the respondent in the case at hand are already suffiecient to establish that he used such trademarks in order to sell merchandise at a commercial scale and that the actual products manufactured by the respondent need not be presented to prove such fact. Also, there were already available samples from the purchases as well as photographs of the particular parts of the merchandise where the trademark in dispute were attached or used, therefore there is no more need for the court to take custody of the countless articles that were seized.

2) NO. In the case at hand there is no criminal action that has been filed. The Court therefore was left with no custody of the highly depreciable merchandise that were seized. More importantly, these highly depreciable articles would have been superfluous if presented as evidence for the following reasons: (1) the respondent had already admitted that he is the owner of the merchandise seized, which made use of the trademarks in dispute; (2) the court required the respondent to execute an undertaking to produce the articles seized when the court requires and had already in its possession a complete inventory of the

items seized as secondary evidence; (3) actual samples of the respondents merchandise are in the possession of the police officers who had applied for the search warrant, and photographs thereof had been made part of the records, and respondent did not dispute that these were obtained from his stores. Where the purpose of presenting as evidence the articles seized is no longer served, there is no justification for severely curtailing the rights of a person to his property. Hence, petition denied.

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