FACTS:

This case involves a petition for review on certiorari filed by Sison Olano, Sergio Ong, Marilyn Go, and Jap Fuk Hai, who are officers and/or directors of Metrotech Steel Industries, Inc. The Department of Justice (DOJ) issued Resolutions finding probable cause for copyright infringement against the petitioners and ordering the withdrawal of the criminal information against them. The respondent, Lim Eng Co, is the Chairman of LEC Steel Manufacturing Corporation. LEC submitted design/drawings and specifications for hatch doors for a project, which were later copied and transferred to the title block of the project's contractor. LEC discovered that Metrotech was manufacturing hatch doors based on its plans and demanded them to cease from infringing its intellectual property rights. Metrotech claimed that no copyright infringement was committed because the hatch doors were patterned according to the drawings provided by the project's contractor.

LEC registered its copyright for the hatch doors with the National Library and filed a complaint for copyright infringement against the petitioners after they refused to stop manufacturing hatch doors based on LEC's plans. The investigating prosecutor dismissed the complaint due to inadequate evidence of copyright infringement, but the DOJ later reversed this decision and directed the filing of criminal information against the petitioners, finding that the hatch doors had artistic or ornamental elements. The petitioners sought to annul the DOJ's Resolutions through a petition for review on certiorari.

Another case involves a dispute over copyright infringement between D.M. Wenceslao and Associates, Inc. (DMWAI) and Lec Steel Manufacturing Corporation (LECM). LECM alleged that DMWAI reproduced its copyrighted hatch doors without authorization, and the DOJ initially found probable cause against DMWAI but later reversed its decision and granted DMWAI's motion for reconsideration, finding no probable cause. LECM filed a motion for reconsideration of the DOJ's decision, which was denied. LECM then filed a petition for certiorari before the Court of Appeals (CA), challenging the DOJ's vacillating findings of probable cause. The CA granted LECM's petition and reinstated the DOJ's decision finding probable cause. DMWAI appealed the CA's decision, arguing against evidence of actual reproduction, claiming that manufacturing hatch doors does not amount to copyright infringement, and questioning the conclusiveness of LECM's copyright registration certificates.

In a separate case, the petitioners were initially charged with copyright infringement by the National Bureau of Investigation (NBI) based on a complaint filed by the private respondent. The DOJ conducted a preliminary investigation and decided to withdraw the criminal information filed against the petitioners. However, the CA reversed this decision, concluding that the DOJ committed grave abuse of discretion. The Supreme Court examined whether the CA erred in finding grave abuse of discretion by the DOJ.

ISSUES:

1. Whether the Court of Appeals erred in concluding that the Department of Justice (DOJ) committed grave abuse of discretion in directing the withdrawal of any criminal information filed against the petitioners.

2. Whether the DOJ's inconsistent findings on the presence or absence of probable cause constitute grave abuse of discretion.

3. Whether there is sufficient evidence to establish copyright infringement.

4. Whether the hatch doors themselves are protected by copyright.

5. Whether the ownership of the copyrighted materials has been proven.

6. Whether the hatch doors in this case are eligible for copyright protection as original artistic works.

7. Whether the design elements of the hatch doors are physically or conceptually separable from the utilitarian aspects of the doors.

8. Whether or not there is a probable cause for copyright infringement against the petitioners.

9. Whether or not the hatch door panel design is original and copyrightable.

RULING:

1. The Court disagreed with the Court of Appeals. The issuance of several resolutions by the DOJ with varying findings of fact and conclusions of law on the existence of probable cause, by itself, is not indicative of grave abuse of discretion. Inconsistent findings and conclusions on the part of the DOJ will denote grave abuse of discretion only if coupled with gross misapprehension of facts, which was not present in this case.

2. The Court found that no grave abuse of discretion was committed by the DOJ in directing the withdrawal of the criminal information against the respondents. A finding of probable cause contradicts the evidence on record, law, and jurisprudence. Probable cause requires the existence of such facts and circumstances as would excite the belief in a reasonable mind that the person charged was guilty of the crime. It does not require an inquiry into whether there is sufficient evidence to procure a conviction.

3. No. The evidence did not substantiate the alleged reproduction of the copyrighted sketches/drawings, as no copies or reproductions were found during the raid. In order to establish copyright infringement, ownership of the copyrighted material and infringement by the respondent must be proven.

4. No. The hatch doors themselves cannot be considered as copyrightable works under class "I" as they do not fall within the statutory subject matter for copyright protection. Only the sketches/drawings depicting the hatch doors were copyrighted.

5. No. The evidence did not establish ownership of the copyrighted materials. The presumption of validity and ownership of a copyright certificate is rebuttable, and in this case, other evidence casts doubt on the ownership.

6. The hatch doors are not eligible for copyright protection as original artistic works. The hatch doors, being objects of utility, are primarily functional and utilitarian in nature, designed to have aesthetic appeal. They do not fall within the definition of copyrightable works as original intellectual creations in the literary and artistic domain.

7. The design elements of the hatch doors are not physically or conceptually separable from the utilitarian aspects of the doors. The allegedly distinct set of hinges and door jamb are related and necessary for the hatch doors to function as apparatuses for emergency egress. Furthermore, the panels of the doors were designed to blend in with the floor, indicating that their design is not independent or separable from the utilitarian function of the doors.

8. The Court held that there is no probable cause for copyright infringement against the petitioners. The Court emphasized that absent originality and copyrightability, no infringement can exist. The design on the hatch door panel was not a product of the petitioners' independent artistic judgment and discretion, but rather a reproduction of an existing design.

9. The Court ruled that the hatch door panel design lacks originality and copyrightability. The design was similar to the wooden floor parquet of the condominium units and was not an original work that could be protected by copyright.

PRINCIPLES:

• Grave abuse of discretion is such capricious and whimsical exercise of judgment as is equivalent to lack of jurisdiction. It must be so patent and gross as to amount to an evasion of positive duty or to a virtual refusal to perform the duty enjoined by or to act at all in contemplation of law.

• Inconsistent findings and conclusions on the part of the DOJ will denote grave abuse of discretion only if coupled with gross misapprehension of facts.

• Probable cause requires the existence of such facts and circumstances as would excite the belief in a reasonable mind that the person charged was guilty of the crime. It does not require an inquiry into whether there is sufficient evidence to procure a conviction.

• In order to establish copyright infringement, ownership of a validly copyrighted material and infringement by the respondent must be proven.

• Copyright protection is limited to the expression of an idea, not the idea itself.

• Copyright can only cover works falling within the statutory enumeration or description.

• The presumption of validity and ownership of a copyright certificate can be rebutted by other evidence that casts doubt on the ownership.

• Copyrightable works refer to original intellectual creations in the literary and artistic domain.

• A useful article, which is an article having an intrinsic utilitarian function without merely portraying appearance or conveying information, is generally not eligible for copyright protection.

• A useful article may be the subject of copyright protection if it incorporates a design element that is physically or conceptually separable from the underlying product.

• To be considered a copyrightable work, a design element of a useful article must be capable of existing independently and must be distinguishable from the utilitarian aspects of the article.

• Valid copyright ownership requires originality, which entails minimal creativity and independent creation by the author.

• Existing articles of manufacture, that are not independently created by the author, cannot be deemed as original creations eligible for copyright protection.

• In order for copyright infringement to subsist, originality and copyrightability are essential elements of a valid copyright ownership.

• Absent originality and copyrightability, no infringement can exist.