Wednesday, June 21, 2017

Case Digest: Philippine Refining co vs. Ng Sam and Director of Patents

Philippine Refining co vs. Ng Sam and Director of Patents
G.R. No. L-26676 July 30, 1982

FACTS:

The sole issue raised in this petition for review of the decision of the Director of patents is whether or not the product of respondent, Ng Sam, which is ham, and those of petitioner consisting of lard, butter, cooking oil and soap are so related that the use of the same trademark "CAMIA" on said goods would likely result in confusion as to their source or origin.

RULING:

The Court held that the businesses of the parties are non-competitive and their products so unrelated that the identical use of the mark ‘Camia” was not likely to give rise to confusion, much less cause damage to petitioner. The particular goods of the parties are so unrelated that consumers would not in any probability mistake one as the source or origin of the product of the other. Petitioner’s goods are basically derived from vegetable oil and animal fats, while the product of respondent is processed from pig's legs.Furthermore, respondent had on his product the business name "SAM'S HAM AND BACON FACTORY" which would place no question on the origin of the product.


The Court also held that the term subject to the case is not uncommon in view of the fact that there were two others distinct businesses bearing the same name. A trademark must be affirmative and definite, significant and distinctive, capable to indicate origin. It was held that if a mark is so commonplace that it cannot be readily distinguished from others, then he who first adopted it cannot be injured by any subsequent appropriation or imitation by others, and the public will not be deceived. What then is to be reckoned with is the similarity of the products under the mark. The similarity is not on the classification of the property or character of the product but on the sameness of the actual product sold or manufactured. Such similarity is wanting in this case.

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