Copyright law of the Philippines

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A copyright is the legal protection extended to the owner of the rights in an original work. [1] Original work refers to every production in the literary, scientific, and artistic domains. [1] The Intellectual Property Office (IPOPHL) is the leading agency responsible for handling the registration and conflict resolution of intellectual property rights and to enforce the copyright laws. [2] IPOPHL was created by virtue of Republic Act No. 8293 or the Intellectual Property Code of the Philippines which took effect on January 1, 1998, under the presidency of Fidel V. Ramos. [3]

Contents

In the Intellectual Property (IP) Code of the Philippines, literary and artistic works include books, writings, musical works, films, paintings, and other works including computer programs. [1]

Works are created on the sole fact of their very creation - regardless of their mode or form of expression as well as their content, the quality of said content, and purpose. [1]

Works covered

Works covered by the copyright law are (1) literary and artistic works and (2) derivative works. On the other hand, works not protected by the copyright law are (1) unprotected subject matter and (2) works of the government.

Literary and artistic works

According to Section 172 of the Intellectual Property Code, [4] literary and artistic works refer to the original and intellectual creations protected from the moment of their creation.

The list of literary and artistic works includes the following:

Derivative works

According to Section 173.2 of the Intellectual Property Code, [4] derivative works are defined as new work provided that they do not violate any subsisting copyright upon the original work employed or any part thereof, or to imply any right to such use of the original works, or to secure or extend copyright in such original works.

The list of derivative works includes the following:

According to Section 174 [4] which refers to the case of a published edition of work, the publisher has the copyright consisting merely of the right of reproduction of the typographical arrangement of the published edition of the work.

Unprotected subject matter

The list of unprotected subject matter include the following:

Works of the government

According to Section 176 of Republic Act 8293, [4] no copyright shall be applied in any work of the Government of the Philippines. To exploit such works for profit, prior approval from the government agency or office should be made. Such agency or office may impose payment of royalties. It is not required to seek prior approval or conditions for the use for any purpose of statutes, rules and regulations, and speeches, lectures, sermons, addresses, and dissertations, pronounced, read or rendered in courts of justice, before administrative agencies, in deliberative assemblies and in meetings of public character.

Ownership

According to Section 178 and 179 of Republic Act 8293, [4] the copyright ownership is under the following rules:

These are the rights that authors are entitled to according to the law of copyright, under Part IV of R.A. 8293, or the Intellectual Property Code of the Philippines.

Economic Rights

This allows a creator to ask for or obtain payment for the use of their work by third parties. [6] According to Section 177 of the Law of Copyright, these rights consist of the right to allow, impede, or carry out the following by the author:

Moral Rights

These rights allow the author of the work to maintain their personal connection to the work, and to undertake measures in order to protect this connection. [4] The author of the work, independent of the economic rights, also have the right to:

Exceptions to moral rights

  • Under Section 195 of the Law on Copyright, an author may waive his moral rights through a written contract. However, this contract is deemed invalid if it allows third parties to do the following:
    • Make use of the author's name, the title of the work, or the author's reputation, in any version or adaptation of the work which could harm or be detrimental to the artistic reputation of another author
    • Make use of an author's name for a piece of work not of his own creation
  • The right of an author to have his contribution to a collective work credited to his name is deemed waived. A collective work here is defined as work created by two or more persons and under the understanding that the work will be attributed to the person whose direction said work is under. It is also understood that contributing natural persons will not be identified. [7]
  • If an author licenses or permits a third party to make use of their work, any necessary transformation, such as arranging, editing, or adaptations of work for use in publications, broadcast, or motion pictures, in accordance with the standards of the medium in which the work is to be used, shall not be found in contrary to the author's rights. In addition, the destruction of work unconditionally and completely transferred by an author shall likewise not be found in violation of the author's rights.

Resale rights

The author and their heirs have the inalienable right to partake of 5% of the proceeds of the sale or lease of their original work (painting, sculpture, manuscript, composition). This inalienable right is in effect during the lifetime of the author, and for fifty years after their death. [4]

Related rights are the rights of those whose help the author avails of in order to assist him in producing his work, and distributing this work to the public. These rights are also referred to as "neighboring rights" and include the following: [1]

Infringement

Acts constituting infringement

Section 216 of Republic Act No. 10372 states that a person infringes a right protected under this Act when one: [8] [9]

Liabilities of infringement

Any person found infringing rights protected under RA 10372 shall be liable: [10]

Instead of recovering actual damages and profits, the copyright owner may file instead for an award of statutory damages for all infringements involved for not less than Fifty thousand pesos (Php 50,000.00). The court may consider the following factors in awarding statutory damages:

Limitations

The following acts shall not constitute infringement of copyright:

The provisions under this shall not be interpreted in a way that exploit the works and does not harm the interest of the right holder. [4]

The Intellectual Property Code of the Philippines does not have a freedom of panorama provision, concerning the right to photograph artistic works in public spaces and use the resulting images for any purposes without the need to secure permission from the authors of the said works. [14]

Fair use

A fair use, in its most general sense, is the act of copying of copyrighted materials done for purposes such as commenting, criticizing, or parodying a copyrighted work without the permission from the copyright owner. It is used as a defense under copyright infringement. [15]

Factors in determining fair use

Under fair use, the use of a copyrighted work for purposes of criticizing, commenting, news reporting, teaching, creating researches, and other similar purposes is not an infringement of copyright. In determining whether the use made is under fair use, the following factors should be considered:

List of reproductions allowed

Given the mentioned rules and regulations above about copyright, reproduction of different materials, without the permission of the author, are still allowed given that they are done for reasons allowed by the Intellectual Property Code of the Philippines. Provided here are the reproductions and purposes allowed by the law.

Reproduction of published work

Under Subsection 187.1 of the Intellectual Property Code of the Philippines, [4] the reproduction of a published work shall be permitted without the owner's authorization given that the reproduction was made for research purposes. The permission granted here shall not extend to:

  • A work of architecture in the form of building or other construction
  • An entire or a substantial part of a book or of a musical work
  • A compilation of data and other materials
  • A computed program except those stated in Section 189
  • Any reproduction that would exploit the work

Reprographic reproduction by libraries

Any library or archive with non-profit purposes may make a single copy of the work without the authorization of the author given that:

  • The work cannot be lent to user in its original form
  • The works are isolated articles contained in composite works or portions of other published works and the reproduction can supply them
  • The making of a copy is for the purposes of preserving or replacing the original in situations that it is destroyed or lost

Reproduction of computer program

The reproduction of one back-up copy of a computer program shall be allowed without the permission of the copyright owner given that the reproduction is for the following uses:

  • The use of the computer program in a computer for which it will be run
  • To create a copy of the original computer program so that replacement is available if the original copy is lost or destroyed

Threshold of originality and the sweat of the brow doctrine

The Intellectual Property Code of the Philippines does not define a threshold of originality that is used to assess whether a particular work can be copyrighted.[ citation needed ]

History

The first known intellectual property law in the Philippines was the Spanish Law on Intellectual Property, which became effective in 1880. The Treaty of Paris which gave the Philippines to the United States has a mention on intellectual property rights: "The rights of property secured by copyrights and patents acquired by Spaniards in the Island of Cuba and in Porto Rico, the Philippines and other ceded territories, at the time of the exchange of the ratifications of this treaty, shall continue to be respected...." In 1924, Act No. 3134 (or An Act to Protect Intellectual Property), based on U.S. Copyright Law of 1909, came into force. This was superseded by Presidential Decree No. 49 during the regime of President Ferdinand Marcos. The current copyright law, Republic Act No. 8293 (Intellectual Property Code of the Philippines), was passed in 1998. [16]

The Philippines was removed from Special 301 Report of the United States Trade Representative (USTR) in 2014, citing "significant legislative and regulatory reforms" in the area of intellectual property. The country began to be listed in 1989 and from 1994 was annually included in the piracy watchlist. The removal was seen as an important factor in boosting investor confidence. [17] As of April 2023 the Philippines remains off the watchlist. [18]

Notable cases

Cases resulting to actions

La Concepcion College vs. Catabijan

Author and publisher Raymund Sta. Maria Catabijan was issued 608,450.00 pesos in damages from La Concepcion College, who he claimed directly copied his work books in order to sell to students. [19] La Concepcion College was found guilty of copyright infringement by the Intellectual Property Office of the Philippines (IPOPHL). [19] The non-sectarian school was hence banned from publishing, selling and distributing copies of Mr. Catabijan's works. [19]

EdCrisch and Alkem vs. UPFA

The Makati Regional Trial Court ruled on November 17, 2020, that EdCrisch International Inc. (EdCrisch) copied a substantial part of Panahon Kasaysayan at Lipunan: Kasaysayan ng Pilipinas textbook, published by the University Press of First Asia (UPFA), for their textbook Pilipinas: Isang Sulyap at Pagyakap. EdCrisch and its Singaporean partner Alkem Company were both mandated by the court to cease production and distributions of the infringing textbook. The court also awarded UPFA ₱9.3 million in damages to be paid by both EdCrisch and Alkem, bringing the 11-year copyright dispute to an end. [20]

St. Mary's vs. Chinese firm and local partners

Fujian New Technology Color Making and Printing Co. Ltd., based in China, and its local partners M.Y. Intercontinental Trading Corporation (MITC) and Allianz Marketing and Publishing Corporation, were ordered to pay ₱24,695,830 worth of damages to St. Mary's Publishing Corporation (SMPC). This stemmed from Fujian's failure to abide by their contract with SMPC to deliver promised textbooks that they printed. The Chinese printing firm instead gave the marketing contract to MITC, with Allianz as the importer. The erring parties were also ordered to stop publications, importations, and distributions of textbooks, inclusive of revised versions. This landmark decision was ruled by Manila City Regional Trial Court Branch 24 on December 8, 2017; the Court of Appeals of the Philippines upheld the decision on April 11, 2019. [21] [22] The latter court said that while Fujian is a foreign company, "its act constitute copyright infringement pursuant to the Berne Convention for the Protection of Literary and Artistic Works," of which the Philippines and China are signatories. [23]

FILSCAP vs. Anrey

The Supreme Court of the Philippines ruled, on August 11, 2022, that Anrey, Inc. must pay ₱10,000 worth of temperate damages to the Filipino Society of Composers, Authors and Publishers, Inc. (FILSCAP) and ₱50,000.00 worth of attorney's fees, all subject to varying interest rates: 12% per year "from September 8, 2009 until June 30, 2013," 6% per year "from July 1, 2013 until finality of the Court's judgment," and 6% per year from the judgment finality "until fully satisfied." The case was in response to the unlicensed use of copyrighted songs from FILSCAP's repertoire in two restaurants in Baguio owned by Anrey, Inc. in 2008. Anrey, Inc. responded to FILSCAP's letters of request to secure proper licensing by claiming their restaurants were playing "whatever was being broadcasted on the radio they were tuned in." Granting FILSCAP's petition for review on  certiorari , the Supreme Court reversed the ruling of Branch 6 of Baguio Regional Trial Court dismissing FILSCAP's complaint as well as the Court of Appeals ruling that upheld the regional trial court's decision. [24]

According to the high court, "the act of playing radio broadcasts containing copyrighted music through the use of loudspeakers (radio-over-loudspeakers) is, in itself, a performance." It added, it does not fall under fair use as the restaurants' manner of use of loudspeakers in transmitting musical content from radio is commercial. The Supreme Court stated that this decision "will also affect other uses in similar establishments like malls, department stores, retail stores, lounges and the like"; [24] an opinion piece by Inquirer.net adds other establishments like hotels, cinemas, office spaces, salons, gymnasiums, and dance clubs, as well as concerts and events. [25] However, the high court stressed that denying FILSCAP's petition would cause great harm to the economic rights of the copyright holders in which the users "use free radio reception" instead of paying royalties. By setting up a precedence for the proper use of copyrighted music, the Court said that this will create "a huge economic impact on the music industry in general." [24]

FILSCAP vs. COSAC

The Supreme Court once again ruled in favor of FILSCAP in another copyright case, in a February 28, 2023 decision. COSAC, Inc., operator of Off the Grill Bar and Restaurant in Quezon City and the erring user, was to pay ₱300,000 worth of unpaid licensing and royalty fees to FILSCAP, inclusive of "12 percent interest per year from February 13, 2006 until June 30, 2013, and at the rate of 6 percent per year from July 1, 2013 until the date of finality of the judgment on the amount." This was a result of the restaurant found by FILSCAP representatives to have played copyrighted music between February 3, 2005 and January 13, 2006, which according to the Court "was not done privately, and the establishment is not a charitable or religious institution or society." The restaurant's distribution of music was also commercial, giving harm to the legitimate interests of the copyright holders, and therefore no longer protected by fair use doctrine. [26] [27]

Cases resulting to dismissals

ABS-CBN vs. Willing Willie

ABS-CBN demanded 127 million pesos from their former reality show star, Willie Revillame, citing copyright infringement due to stark similarities in Revillame's show, Willing Willie, and ABS CBN's Wowowee. [28] ABS-CBN listed 5 acts of plagiarism allegedly committed by Willing Willie in their complaint as follows: [28]

  1. Willing Willie's opening song and dance number was similar to that of Wowowee's [28]
  2. “BIGA-Ten” and “Big Time Ka,” both segments from the shows involved, bear similar names. [28]
  3. “Willie of Fortune” and “Willtime Bigtime” are segments from both shows which resemble each other. [28] ABS-CBN claimed that Willtime Bigtime resembled its show as it also showcases contestants relaying their personal stories before proceeding to play a singing/trivia game. [28]
  4. April “Congratulations” Gustilo is one of several backup dancers from Wowowee who also appear in Willing Willie. [28]
  5. Other striking similarities ABS-CBN claimed are found in Willing Willie's set design, stage, studio viewers' seats lay-out, lighting angles and camera angles. [28]

A 25-page ruling later on dated May 22, 2015, junked the case against Revillame, declaring it moot. [28] After the Quezon City RTC demanded a 400 million peso bond from Revillame to answer any further damage the network might sustain, it was later discharged. [28] Revillame signed a contract with GMA network two days prior to the ruling, to work on a new show entitled, “Wowowin." [28]

BJ Productions, Inc, produced a dating game show Rhoda and Me which aired from 1970 to 1977. On July 14, 1991, Francisco Joaquin, Jr., president of BJPI, saw on RPN Channel 9 an episode of It's a Date, produced by IXL Productions, Inc. (IXL) with similar format of his dating show. Joaquin filed a case against IXL Productions, headed by Gabriel Zosa and RPN 9 before Regional Trial Court of Quezon City. Meanwhile, Zosa sought a review of the resolution of the Assistant City Prosecutor before the Secretary of Justice Franklin Drilon. On August 12, 1992, Drilon reversed the Assistant City Prosecutor's findings and directed him to move for the dismissal of the case against private respondents. Joaquin filed a motion for reconsideration, but his motion denied by Drilon on December 3, 1992. [29]

The Supreme Court ruled on January 28, 1999, that the format or mechanics of a television show is not included in the list of the protected work provided by Presidential Decree no. 49 and Republic Act No. 8293. It further state that copyright, in the strict sense of the term, is purely a statutory right and does not extend to an idea, procedure, process, system, method or operation, concept, principles or discovery regardless of the form to which it is described, explained, and illustrated or embodied in the work. [29]

Pearl & Dean Philippines vs. Shoemart

Pearl & Dean Philippines is an out-of-home advertising company. In 1985, Pearl and Dean negotiated with Shoemart, Inc. (now SM Prime Holdings) for the lease and installation of lightboxes (two-sided structures lit by fluorescent lighting often used for advertising and store/mall directories) in SM Makati and SM Cubao. Only SM Makati was signed but later rescinded by Pearl & Dean due to non-performance of their terms. Years later, Pearl & Dean found out that exact copies of its light boxes were installed at different SM stores. It was further discovered that SM's sister company North Edsa Marketing Inc. (NEMI), sold advertising space in lighted display units located in SM's different branches. [30]

Pearl & Dean filed this instant case for infringement of trademark and copyright, unfair competition and damages. SM on its part maintained that it independently developed its poster panels using commonly known techniques and available technology, without notice of or reference to Pearl and Dean's copyright. [30] Makati Regional Trial Court decided in favor of Pearl & Dean, finding SM and NEMI jointly and severally liable for infringement of copyright and infringement of trademark. On appeal, however, the Court of Appeals reversed the trial court. On August 15, 2003, Supreme Court strengthened the Court of Appeals' decision by stating Pearl & Dean never secured a patent for the light boxes and the copyright patent is on its technical drawings within the category of "pictorial illustrations." [30] It applied the similar ruling of G.R. No. 108946 (Joaquin, Jr. v. Drilon). [29]

2016 ruling requiring evidence over suspicion

On G.R. No. 195835, penned March 14, 2016, the Supreme Court ruled that For a claim of copyright infringement to prevail, the evidence on record must demonstrate: (1) ownership of a validly copyrighted material by the complainant; and (2) infringement of the copyright by the respondent. It further stated that probable cause is not imputable against the respondent. [31]

The ruling stemmed from a dispute between LEC Steel Manufacturing Corporation and Metrotech Steel Industries where the former accused the latter infringing its intellectual property rights. [31] The LEC failed to substantiate the alleged reproduction of the drawings/sketches of hatch doors it copyrighted had had no proof that the Metrotech reprinted the copyrighted sketches/drawings of LEC's hatch doors. The raid conducted by the NBI on Metrotech's premises yielded no copies or reproduction of LEC's copyrighted sketches/drawings of hatch doors. What were discovered instead were finished and unfinished hatch doors. [31]

Related Research Articles

<span class="mw-page-title-main">Copyright</span> Legal concept regulating rights of a creative work

A copyright is a type of intellectual property that gives the creator of an original work, or another right holder, the exclusive and legally secured right to copy, distribute, adapt, display, and perform a creative work, usually for a limited time. The creative work may be in a literary, artistic, educational, or musical form. Copyright is intended to protect the original expression of an idea in the form of a creative work, but not the idea itself. A copyright is subject to limitations based on public interest considerations, such as the fair use doctrine in the United States.

Anti-circumvention refers to laws which prohibit the circumvention of technological barriers for using a digital good in certain ways which the rightsholders do not wish to allow. The requirement for anti-circumvention laws was globalized in 1996 with the creation of the World Intellectual Property Organization's Copyright Treaty.

<i>Théberge v Galerie dArt du Petit Champlain Inc</i> Supreme Court of Canada case

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Copyright in the Netherlands is governed by the Dutch Copyright Law, copyright is the exclusive right of the author of a work of literature or artistic work to publish and copy such work.

The Copyright Act 1957 as amended governs the subject of copyright law in India. The Act is applicable from 21 January 1958. The history of copyright law in India can be traced back to its colonial era under the British Empire. The Copyright Act 1957 was the first post-independence copyright legislation in India and the law has been amended six times since 1957. The most recent amendment was in the year 2012, through the Copyright (Amendment) Act 2012.

<span class="mw-page-title-main">Copyright, Designs and Patents Act 1988</span> United Kingdom law

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<span class="mw-page-title-main">Freedom of panorama</span> Permissive provision in copyright laws

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The copyright law of Australia defines the legally enforceable rights of creators of creative and artistic works under Australian law. The scope of copyright in Australia is defined in the Copyright Act 1968, which applies the national law throughout Australia. Designs may be covered by the Copyright Act as well as by the Design Act. Since 2007, performers have moral rights in recordings of their work.

The copyright law of the United States grants monopoly protection for "original works of authorship". With the stated purpose to promote art and culture, copyright law assigns a set of exclusive rights to authors: to make and sell copies of their works, to create derivative works, and to perform or display their works publicly. These exclusive rights are subject to a time and generally expire 70 years after the author's death or 95 years after publication. In the United States, works published before January 1, 1929, are in the public domain.

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References

  1. 1 2 3 4 5 "ABOUT COPYRIGHT". ipophil.gov.ph. Archived from the original on April 20, 2017. Retrieved April 9, 2017.
  2. ↑ "ABOUT INTELLECTUAL PROPERTY OFFICE". ipophil.gov.ph. Archived from the original on April 20, 2017. Retrieved April 15, 2017.
  3. ↑ "ABOUT INTELLECTUAL PROPERTY OFFICE". ipophl.gov.ph. Archived from the original on April 20, 2017. Retrieved April 15, 2017.
  4. 1 2 3 4 5 6 7 8 9 "Republic Act No. 8293: An Act Prescribing the Intellectual Property Code and establishing the Intellectual Property Office, Providing for its Powers and Functions, and for Other Purposes" (PDF). 1998. Archived from the original (PDF) on December 13, 2016. Retrieved April 15, 2017.
  5. ↑ (see Sec. 6, P.D. 49a) https://www.officialgazette.gov.ph/1972/11/14/presidential-decree-no-49-s-1972/
  6. ↑ Controller, Backup. "About Copyright". www.ipophil.gov.ph. Archived from the original on April 20, 2017. Retrieved April 15, 2017.
  7. ↑ Firm, Joselito Guianan Chan, Managing Partner, Chan Robles and Associates Law. "INTELLECTUAL PROPERTY CODE OF THE PHILIPPINES [FULL TEXT] - CHAN ROBLES VIRTUAL LAW LIBRARY". www.chanrobles.com. Retrieved April 15, 2017.{{cite web}}: CS1 maint: multiple names: authors list (link)
  8. ↑ "(Sec. 216, R.A. 10372)". Official Gazette. Retrieved April 15, 2017.
  9. ↑ Hechanova, Editha. "IP Code Amendments Good for IP Owners". Managing Intellectual Property. Retrieved April 15, 2017.
  10. ↑ "(Sec. 216(1), R.A. 10372)". Official Gazette. Retrieved April 15, 2017.
  11. ↑ (Sec. 10(1), P.D. 49) https://www.officialgazette.gov.ph/1972/11/14/presidential-decree-no-49-s-1972/
  12. ↑ (Sec. 11, third par., P.D. 49) https://www.officialgazette.gov.ph/1972/11/14/presidential-decree-no-49-s-1972/
  13. ↑ (Sec. 11, P.D. 49) https://www.officialgazette.gov.ph/1972/11/14/presidential-decree-no-49-s-1972/
  14. ↑ Reyes, Mary Ann LL. (November 28, 2021). "Changing landscape of copyright". The Philippine Star . Retrieved February 3, 2022.
  15. ↑ Stim, Richard (2010). Getting Permission How to License & Clear Copyrighted Materials Online & Offline, 4th Edition. United States: Delta Printing Solutions, Inc. p. 244.
  16. ↑ "The intellectual property system: a brief history". IPOPHL. Retrieved May 31, 2023.
  17. ↑ "U.S. removes Philippines from piracy watch list after 20 years". Reuters. April 29, 2014. Retrieved May 31, 2023.
  18. ↑ "USTR keeps PH out of watchlist for 10 years, cites best practices in IP awareness". IPOPHL. April 28, 2023. Retrieved May 31, 2023.
  19. 1 2 3 "Bulacan school ordered to pay P608,450 for copyright infringement". Newsbytes. November 8, 2014.
  20. ↑ Bernardo, Jaehwa (February 18, 2021). "Makati court resolves 11-year copyright battle". ABS-CBN News . Retrieved September 25, 2021.
  21. ↑ Torres-Tupas, Tetch (June 2, 2019). "CA affirms copyright case ruling; Chinese firm, local partners ordered to pay over P20M damages". Inquirer.net . Retrieved October 19, 2021.
  22. ↑ Canlas, Jomar (June 3, 2019). "Chinese firm guilty of copyright infringement". The Manila Times . Retrieved October 19, 2019.
  23. ↑ Requejo, Rey E. (June 2, 2019). "Infringement on copyright vs Chinese trader upheld". Manila Standard . Retrieved October 19, 2021.
  24. 1 2 3 "SC Champions FILSCAP's Rights over Copyrighted Works". Supreme Court of the Philippines . August 11, 2022. Retrieved August 23, 2022.
  25. ↑ "Striking the right note". Inquirer.net . August 18, 2022. Retrieved August 24, 2022.
  26. ↑ Ordoñez, John Victor (July 30, 2023). "High Court punishes restaurant for playing copyrighted music in public". BusinessWorld. Retrieved November 30, 2023.
  27. ↑ San Juan, Joel R. (August 1, 2023). "Court upholds FILSCAP's authority to protect copyrighted musical works". BusinesssMirror. Retrieved November 30, 2023.
  28. 1 2 3 4 5 6 7 8 9 10 11 "ABS-CBN files P127-M copyright case vs. 'Willing Willie'" Archived February 24, 2020, at the Wayback Machine , "ABS-CBN", November 25, 2010
  29. 1 2 3 "G.R. No. 108946, Joaquin, Jr. v. Drilon", "lawphil.net", September 9, 2020
  30. 1 2 3 "G.R. No. 148222, Pearl & Dean Philippines v. Shoemart", "lawphil.net", September 9, 2020
  31. 1 2 3 "G.R. No. 195835, SISON OLAÑO, SERGIO T. ONG, MARILYN O. GO, AND JAP FUK HAI, vs. LIM ENG CO", "Chan Robles Law Library", September 9, 2020
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