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Sison Olaño, Sergio T. Ong, Marilyn O. Go, and Jap Fuk Hai vs. Lim Eng Co
G.R. No. 195835 | March 20, 2019

FACTS:

The petitioners are officers and/or directors of Metrotech Steel Industries, Inc.
(Metrotech), while Lim Eng Co is the Chairman of LEC Steel Manufacturing Corporation (LEC).
LEC accused the petitioners of copyright infringement after the latter fabricated hatch doors
similar to the design made by the former. The petitioners denied this accusation, claiming that
copyright protection does not extend to the objects depicted in illustrations and plans. After
several resolutions, the case was brought to the Court of Appeals where it ruled in favor of LEC.

ISSUES:

Whether or not there was infringement of copyright.

RULING:

There was no copyright infringement.

To constitute infringement, the usurper must have copied or appropriated the original
work of an author or copyright proprietor, absent copying, there can be no infringement of
copyright.

The Supreme Court ruled that the respondent failed to substantiate the alleged
reproduction of the drawings/sketches of hatch doors copyrighted under Certificate of
Registration Nos. 1-2004-14. The raid conducted by the NBI in Metrotech’s premises yielded no
copies or reproduction of LEC’s copyrighted sketches/drawings of hatch doors.

The high court further ruled that LEC’s hatch doors bore no design elements that are
physically and conceptually separable, independent and distinguishable from the hatch door itself.
Being articles of manufacture already in existence, the hatch doors cannot be deemed as original
creations.

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