FACTS:

The case involves multiple disputes between two separate parties: Dockers USA and Clinton Apparelle, Inc., and LS & Co., Inc. (LS & Co.) and Levi Strauss (Philippines), Inc. (LSPI) against Clinton Apparelle, Inc. In the first case, Dockers USA filed a complaint against Clinton Apparelle, alleging trademark infringement. Dockers USA sought to prevent the use of a design on Clinton Apparelle's jeans that was similar to Dockers USA's "DOCKERS and DESIGN" trademark. The trial court granted a temporary restraining order (TRO) and later issued a writ of preliminary injunction without discussing the merits of the case. In the second case, LS & Co. and LSPI filed a complaint for trademark infringement and damages against Clinton Apparelle, Inc., alleging that the use of the mark "Collezione Levi's" was likely to deceive or cause confusion among consumers. The trial court granted a preliminary injunction in favor of LS & Co. and LSPI, preventing Clinton Apparelle, Inc. from using the mark. The Court of Appeals reversed both trial court decisions in separate cases, prompting Dockers USA and LS & Co. to file petitions with the Supreme Court. Clinton Apparelle, Inc. argued that only questions of law may be raised on appeal.

ISSUES:

1. Whether the issuance of the writ of preliminary injunction by the trial court was proper.

2. Whether the Court of Appeals erred in setting aside the orders of the trial court.

3. Whether there was sufficient justification for the issuance of the writ of preliminary injunction.

4. Whether the single registration of the trademark "Dockers and Design" confers on the owner the right to prevent the use of a fraction of the trademark.

5. Whether the use of a portion of a registered trademark constitutes a material or substantial invasion of the owner's right.

6. Whether the wing-shaped logo is the dominant or central feature of the trademark "Dockers and Design".

7. Whether the erosion or dilution of a trademark is protectable even without actual profit or damage to the trademark owner.

8. Whether the petitioners have established the elements necessary for protection against trademark dilution.

9. Whether the trial court erred in granting the injunctive relief without sufficient basis and in violation of the requirements set forth by jurisprudence.

RULING:

1. The Court of Appeals did not err in setting aside the orders of the trial court. The issuance of a writ of preliminary injunction is an extraordinary remedy that should only be granted when there is a pressing necessity to avoid injurious consequences that cannot be remedied under any standard compensation. In this case, the trial court failed to show that petitioners had a clear and positive right that needed protection, as well as a showing that the acts complained of violated their rights. Therefore, the Court of Appeals was correct in overturning the orders of the trial court.

2. There was scant justification for the issuance of the writ of preliminary injunction as the right to injunctive relief was not clearly and unmistakably demonstrated. The right has yet to be determined and petitioners failed to show material and substantial invasion of their right or any urgent and permanent necessity for the writ.

3. The right to prevent the use of a fraction of a registered trademark is not evident as the single registration of the trademark "Dockers and Design" does not clearly confer such right.

4. It is unclear whether the use of a portion of a registered trademark constitutes a material or substantial invasion of the owner's right, which can only be established through a full-blown trial.

5. It is not settled whether the wing-shaped logo is the dominant or central feature of the trademark "Dockers and Design", and further evidentiary proceedings are needed to determine this issue.

6. The erosion or dilution of a trademark may be protectable, but the petitioners have failed to establish that their trademark "Dockers and Design" has acquired a strong degree of distinctiveness and have not shown the necessary elements for protection from dilution.

7. The petitioners have yet to establish whether their trademark is famous and distinctive, whether the use by the respondent of "Paddocks and Design" began after petitioners' mark became famous, and whether such use defames petitioners' mark.

8. The Court held that the trial court erred in granting the injunctive relief without sufficient basis and in violation of the requirements set forth by jurisprudence. The trial court's statement that "the plaintiffs appear to be entitled to the relief prayed for" and that the "paramount interest of justice will be better served if the status quo shall be maintained" falls short of the requirement of showing a clear right to it and that the need for its issuance must be established by clear and convincing evidence. It is not enough for the trial court to simply state that it appears that the plaintiffs are entitled to the relief prayed for. The Court also agreed with the Court of Appeals that the damages suffered by the petitioners can be compensated through monetary consideration, which negates the need for injunctive relief. The Court further held that the issued injunctive writ, if allowed, would dispose of the case on the merits without trial, which is not proper. The courts should avoid issuing a writ of preliminary injunction that would effectively dispose of the main case without trial. The Court also found that the Court of Appeals went beyond its authority in declaring that there is no confusion between the two logos involved in the case, as this issue remains to be decided by the trial court. Finally, the Court found that the trial court's procedure and the opportunity given to the respondents to be heard complied with the requirements of due process.

PRINCIPLES:

• Injunction is an extraordinary remedy used to preserve or maintain the status quo of things.

• The issuance of a writ of preliminary injunction rests upon the existence of an emergency or special recourse before the main case can be heard in due course of proceedings.

• A clear and positive right, calling for judicial protection, must be shown to justify the issuance of a preliminary injunction.

• Injunction will not issue to protect contingent, abstract, or future rights. There must exist an actual right.

• The trial court's exercise of discretion in injunctive matters is generally not interfered with unless there is manifest abuse.

• Injunction should be issued with caution and deliberation, only in cases of great injury where there is no commensurate remedy in damages.

• The Certificate of Registration of a trademark is prima facie evidence of the validity of the registration and the owner's exclusive right to use the mark.

• Trademark dilution protects famous marks from subsequent uses that blur distinctiveness or tarnish/disparage the mark.

• To be eligible for protection from dilution, there must be a finding that the trademark is famous and distinctive, the use by the alleged infringer began after the mark became famous, and such subsequent use defames the mark.

• The trial court must state its own findings of fact and cite particular law to justify the grant of preliminary injunction.

• The grant of a preliminary injunction must be based on clear legal right and injury that will be sustained without its issuance. The burden of proof is on the party seeking injunctive relief to establish these requisites.

• A writ of injunction should not be issued when an action for damages can adequately compensate the injuries caused.

• Courts should avoid issuing a writ of preliminary injunction that would effectively dispose of the main case without trial.

• Premature statements on issues that remain to be decided by the trial court should be avoided.

• Due process requires an opportunity to be heard, but a trial-type hearing is not always essential in applications for preliminary injunctions.

• In the absence of proof of a legal right and the injury sustained by the applicant, an order granting the issuance of an injunctive writ will be set aside for having been issued with grave abuse of discretion.