United Features Syndicate v. Munsingwear
[GR 76193, Nov. 9, 1989]
Section 2 of Presidential Decree No. 49, otherwise known
as the "Decree on Intellectual Property", provides:
"Section 2. The rights granted by this Decree shall,
from the moment of creation, subsist with respect to any of
the following classes of works:
xxx xxx xxx
"(O) Prints, pictorial illustrations, advertising copies,
labels, tags and box wraps. . . ."
Therefore, since the name "CHARLIE BROWN" and its
pictorial representation were covered by a copyright registration
way back in 1950 the same are entitled to protection under
PD No. 49. Aside from its copyright registration, petitioner
is also the owner of several trademark registrations and application
for the name and likeness of "CHARLIE BROWN" which
is the duly registered trademark and copyright of petitioner
United Feature Syndicate Inc. as early as 1957 and additionally
also as TV SPECIALS featuring the "PEANUTS" characters
and "CHARLIE BROWN".
In upholding the right of the petitioner to maintain the
present suit before our courts for unfair competition or infringement
of trademarks of a foreign corporation, we are moreover recognizing
our duties and the rights of foregoing states under the Paris
Convention for the Protection of Industrial Property to which
the Philippines is a party. We are simply interpreting a solemn
international commitment of the Philippines embodied in a
multilateral treaty to which we are a party and which we entered
into because it is in our national interest to do so.
See also FILSCAP
v. Tan, L-36402, Mar. 16, 1987, Ibid.