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MANUEL P. SAMSON v. CA

FACTS:

Manuel P. Samson filed a petition for review of the Decision of the Court of Appeals in a dispute over the "OTTO" trademark. Samson applied for the registration of the "OTTO" trademark for different products, while Wilfro Luminlun also filed for the registration of the same trademark for specific items. On 29 December 1983, Samson allowed Luminlun to use the "OTTO" trademark for jeans only. However, Samson later revoked Luminlun's authority to use the trademark and demanded him to stop producing and distributing "OTTO" jeans. Luminlun filed a complaint questioning the revocation's validity, resulting in a trial court ruling in Samson's favor. Nevertheless, the Court of Appeals reversed the decision on appeal and awarded damages to Luminlun. Samson then filed this petition, alleging various errors committed by the Court of Appeals in its ruling.

ISSUES:

  1. Whether the revocation of the Authority to Use Trademark was justified.

  2. Whether Luminlun sustained actual or compensatory damages as a consequence of the revocation.

  3. Whether the award of attorney's fees was justified.

  4. Whether the trial court's award of moral damages and attorney's fees in favor of Samson should be sustained.

RULING:

  1. The Court of Appeals erred in concluding that the revocation of the Authority to Use Trademark made by Samson was unjustified. The Court of Appeals also erred in awarding actual or compensatory damages to Luminlun without sufficient evidence to prove such damages. Additionally, the Court of Appeals erred in awarding attorney's fees without any legal ground for such award. However, the Court of Appeals' decision in not sustaining the trial court's award of moral damages and attorney's fees in favor of Samson was not discussed further and remains unresolved.

PRINCIPLES:

  • Revocation of Authority to Use Trademark may be justified when there is a violation of the terms and conditions of the authority granted.

  • Actual or compensatory damages must be proven with sufficient evidence.

  • Attorney's fees must have a legal basis for the award.

  • Moral damages may be granted in appropriate cases.