Malang v. McCullough
[GR L-19439, Oct. 31, 1964]

An intellectual creation should be copyrighted within the periods provided by law, failure of which renders such creation public property.

For there to be a limited publication or prohibition, such fact must appear on the face of the design. When the purpose is a limited publication, but the effect is a general publication, irrevocable rights thereon become vested in the general public.

The author of a literary composition has a right to the first publication thereof. He has a right to determine whether it shall be published at all, and if published, when, where, by whom, and in what form. This exclusive right is confined to the first publication. Once published, it is dedicated to the public, and the author loses the exclusive right to control subsequent publication by others, unless the work is placed under the protection of the copyright law.