Caterpillar v. Manolo P. Samson

Summary

Caterpillar Inc. filed criminal and civil cases against Samson for unfair competition and trademark infringement. The Supreme Court consolidated two cases: one involving suspension of criminal proceedings due to alleged prejudicial question, and another challenging DOJ's finding of no probable cause. The Court ruled that civil trademark cancellation actions are independent under Civil Code Article 33 and cannot suspend criminal proceedings for unfair competition. However, it upheld DOJ's determination that no probable cause existed for criminal charges, recognizing Samson's valid 1997 trademark registration and prior use since 1992. The decision emphasizes the separation between civil and criminal IP actions and respects executive discretion in probable cause determinations absent grave abuse of discretion.