Manly Sportwear Manufacturing v. Dadodette Enterprises (G.R. No. 165306)

Facts:

On the basis of information that respondent Dadodette Enterprises were in possession of sporting goods or articles, the copyright of which belonged to petitioner Manly, the NBI applied for search warrant before the trial court which ruled on its issuance. Thereafter, respondent moved to quash the warrant on the ground that petitioner’s goods are ordinary and not among the works protected under the IP Code. The trial court annulled the warrant holding that there were certificates of registration over the same goods issued earlier than that of petitioner negating its claim that the goods were original works entitled to copyright protection. CA affirmed.

Issue:

Whether or not the certificates of registration issued to petitioner is proof of its ownership.

Ruling: NO.

Besides, no copyright accrues in favor of MANLY despite issuance of the certificates of registration and deposit pursuant to Section 2, Rule 7 of the Copyrights Safeguards and Regulations which states:

Sec. 2 Effects of Registration and Deposit of Work. The registration and deposit of the work is purely for recording the date of registration and deposit of the work and shall not be conclusive as to copyright ownership or the term of the copyrights or the rights of the copyright owner, including neighboring rights.

At most, the certificates of registration and deposit issued by the National Library and the Supreme Court Library serve merely as a notice of recording and registration of the work but do not confer any right or title upon the registered copyright owner or automatically put his work under the protective mantle of the copyright law. It is not a conclusive proof of copyright ownership. As it is, non-registration and deposit of the work within the prescribed period only makes the copyright owner liable to pay a fine.

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