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LYCEUM OF PHILIPPINES v. CA

FACTS:

Petitioner, an educational institution, filed a case before the SEC to compel the private respondents, also educational institutions, to delete the word "Lyceum" from their corporate names and permanently enjoin them from using "Lyceum". Some of the private respondents participated in the proceedings, while others were declared in default. The case stemmed from a previous SEC case where petitioner sought to require the Lyceum of Baguio, Inc. to change its name, which was later denied by the Supreme Court. Petitioner then wrote other educational institutions using the word "Lyceum" in their name, advising them to discontinue using it. When this failed, petitioner filed the current case before the SEC to enforce its exclusive right to use the word "Lyceum". The SEC hearing officer ruled in favor of petitioner, but the decision was reversed by the SEC En Banc, stating that there was no confusion among the public due to the presence of geographical names in the corporate names. The Court of Appeals affirmed the decision of the SEC En Banc, prompting petitioner to file an appeal before the Supreme Court.

ISSUES:

  1. Whether the corporate names of the private respondent institutions are "identical with, or deceptively or confusingly similar" to that of the petitioner institution.

  2. Whether the word "Lyceum" has acquired a secondary meaning in relation to the petitioner.

  3. Whether the appellant has acquired secondary meaning over the word "Lyceum" in its corporate name.

  4. Whether confusion will arise if other educational institutions use the same word "Lyceum".

RULING:

  1. The corporate names of the private respondent institutions are not "identical with, or deceptively or confusingly similar" to that of the petitioner institution. The addition of geographic names to the word "Lyceum" effectively precludes confusion and deception, and it is unlikely that the general public would mistake the private respondent institutions for the petitioner institution.

  2. The word "Lyceum" has not acquired a secondary meaning in relation to the petitioner. The doctrine of secondary meaning, which originated in trademark law, applies to corporate names as well. However, the use of "Lyceum" in the petitioner's corporate name has not been exclusive or associated with the petitioner in the mind of the general public. There is no evidence to prove that the word "Lyceum" has become distinctive and associated exclusively with the petitioner institution.

  3. The Court held that the appellant has failed to prove that it had acquired secondary meaning over the word "Lyceum" and that confusion will arise if other educational institutions use the same word. The Court affirmed the Decision of the Court of Appeals denying the appellant's petition for lack of merit.

PRINCIPLES:

  • The use of geographic names in corporate names can effectively preclude confusion and deception.

  • The word "Lyceum" is generic in character and commonly refers to a school or an institution of learning.

  • The doctrine of secondary meaning, which applies to trademarks, can also apply to corporate names.

  • In order for a corporate name to acquire secondary meaning, it must be used exclusively and associated with the entity for a considerable period of time, and must have acquired goodwill and a well-known reputation.

  • The exclusive right to use a corporate name must be attended with exclusivity and secondary meaning.

  • The use of a word alone for a long period of time does not automatically mean it has acquired secondary meaning.

  • In determining whether a corporate name is identical or confusingly similar, the entirety of the names must be evaluated and not just the presence of a single word.