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Republic of the Philippines

SUPREME COURT
Manila
SECOND DIVISION
G.R. No. 154491

November 14, 2008

COCA-COLA BOTTLERS, PHILS., INC. (CCBPI), Naga Plant, petitioner,


vs.
QUINTIN J. GOMEZ, a.k.a. "KIT" GOMEZ and DANILO E. GALICIA, a.k.a.
"DANNY GALICIA",respondents.
DECISION
BRION, J.:
Is the hoarding of a competitor's product containers punishable as unfair
competition under the Intellectual Property Code (IP Code, Republic Act No.
8293) that would entitle the aggrieved party to a search warrant against the
hoarder? This is the issue we grapple with in this petition for review on
certiorari involving two rival multinational softdrink giants; petitioner Coca-Cola
Bottlers, Phils., Inc. (Coca-Cola) accuses Pepsi Cola Products Phils., Inc.
(Pepsi), represented by the respondents, of hoarding empty Coke bottles in bad
faith to discredit its business and to sabotage its operation in Bicolandia.
BACKGROUND
The facts, as culled from the records, are summarized below.
On July 2, 2001, Coca-Cola applied for a search warrant against Pepsi for
hoarding Coke empty bottles in Pepsi's yard in Concepcion Grande, Naga City,
an act allegedly penalized as unfair competition under the IP Code. Coca-Cola
claimed that the bottles must be confiscated to preclude their illegal use,
destruction or concealment by the respondents. 1 In support of the application,
Coca-Cola submitted the sworn statements of three witnesses: Naga plant
representative Arnel John Ponce said he was informed that one of their plant
security guards had gained access into the Pepsi compound and had seen
empty Coke bottles; acting plant security officer Ylano A. Regaspi said he
investigated reports that Pepsi was hoarding large quantities of Coke bottles by
requesting their security guard to enter the Pepsi plant and he was informed by
the security guard that Pepsi hoarded several Coke bottles; security
guard Edwin Lirio stated that he entered Pepsi's yard on July 2, 2001 at 4 p.m.
and saw empty Coke bottles inside Pepsi shells or cases. 2

Municipal Trial Court (MTC) Executive Judge Julian C. Ocampo of Naga City,
after taking the joint deposition of the witnesses, issued Search Warrant No.
2001-013 to seize 2,500 Litro and 3,000 eight and 12 ounces empty Coke
bottles at Pepsi's Naga yard for violation of Section 168.3 (c) of the IP
Code.4 The local police seized and brought to the MTC's custody 2,464 Litro
and 4,036 eight and 12 ounces empty Coke bottles, 205 Pepsi shells for Litro,
and 168 Pepsi shells for smaller (eight and 12 ounces) empty Coke bottles, and
later filed with the Office of the City Prosecutor of Naga a complaint against two
Pepsi officers for violation of Section 168.3 (c) in relation to Section 170 of the
IP Code.5The named respondents, also the respondents in this petition, were
Pepsi regional sales managerDanilo E. Galicia (Galicia) and its Naga general
manager Quintin J. Gomez, Jr. (Gomez).
In their counter-affidavits, Galicia and Gomez claimed that the bottles came
from various Pepsi retailers and wholesalers who included them in their return
to make up for shortages of empty Pepsi bottles; they had no way of
ascertaining beforehand the return of empty Coke bottles as they simply
received what had been delivered; the presence of the bottles in their yard was
not intentional nor deliberate; Ponce and Regaspi's statements are hearsay as
they had no personal knowledge of the alleged crime; there is no mention in the
IP Code of the crime of possession of empty bottles; and that the ambiguity of
the law, which has a penal nature, must be construed strictly against the State
and liberally in their favor. Pepsi security guards Eduardo E. Miral and Rene
Acebuche executed a joint affidavit stating that per their logbook, Lirio did not
visit or enter the plant premises in the afternoon of July 2, 2001.
The respondents also filed motions for the return of their shells and to quash
the search warrant. They contended that no probable cause existed to justify
the issuance of the search warrant; the facts charged do not constitute an
offense; and their Naga plant was in urgent need of the shells.
Coca-Cola opposed the motions as the shells were part of the evidence of the
crime, arguing that Pepsi used the shells in hoarding the bottles. It insisted that
the issuance of warrant was based on probable cause for unfair competition
under the IP Code, and that the respondents violated R.A. 623, the law
regulating the use of stamped or marked bottles, boxes, and other similar
containers.
THE MTC RULINGS
On September 19, 2001, the MTC issued the first assailed order 6 denying the
twin motions. It explained there was an exhaustive examination of the applicant
and its witnesses through searching questions and that the Pepsi shells are
prima facie evidence that the bottles were placed there by the respondents.

In their motion for reconsideration, the respondents argued for the quashal of
the warrant as the MTC did not conduct a probing and exhaustive examination;
the applicant and its witnesses had no personal knowledge of facts surrounding
the hoarding; the court failed to order the return of the "borrowed" shells; there
was no crime involved; the warrant was issued based on hearsay evidence;
and the seizure of the shells was illegal because they were not included in the
warrant.
On November 14, 2001, the MTC denied the motion for reconsideration in the
second assailed order,7 explaining that the issue of whether there was unfair
competition can only be resolved during trial.
The respondents responded by filing a petition for certiorari under Rule 65 of
the Revised Rules of Court before the Regional Trial Court (RTC) of Naga City
on the ground that the subject search warrant was issued without probable
cause and that the empty shells were neither mentioned in the warrant nor the
objects of the perceived crime.
THE RTC RULINGS
On May 8, 2002, the RTC voided the warrant for lack of probable cause and the
non-commission of the crime of unfair competition, even as it implied that other
laws may have been violated by the respondents. The RTC, though, found no
grave abuse of discretion on the part of the issuing MTC judge. 8 Thus,
Accordingly, as prayed for, Search Warrant No. 2001-02 issued by the
Honorable Judge Julian C. Ocampo III on July 2, 2001 is ANNULLED
and SET ASIDE. The Orders issued by the Pairing Judge of Br. 1,
MTCC of Naga City dated September 19, 2001 and November 14,
2001 are also declared VOID and SET ASIDE. The City Prosecutor of
Naga City and SPO1 Ernesto Paredes are directed to return to the
Petitioner the properties seized by virtue of Search Warrant No. 200102. No costs.
SO ORDERED.9
In a motion for reconsideration, which the RTC denied on July 12, 2002, the
petitioner stressed that the decision of the RTC was contradictory because it
absolved Judge Ocampo of grave abuse of discretion in issuing the search
warrant, but at the same time nullified the issued warrant. The MTC should
have dismissed the petition when it found out that Judge Ocampo did not
commit any grave abuse of discretion.
Bypassing the Court of Appeals, the petitioner asks us through this petition for
review on certiorariunder Rule 45 of the Rules of Court to reverse the decision

of the RTC. Essentially, the petition raises questions against the RTC's
nullification of the warrant when it found no grave abuse of discretion
committed by the issuing judge.
THE PETITION and
THE PARTIES' POSITIONS
In its petition, the petitioner insists the RTC should have dismissed the
respondents' petition for certiorari because it found no grave abuse of discretion
by the MTC in issuing the search warrant. The petitioner further argues that the
IP Code was enacted into law to remedy various forms of unfair competition
accompanying globalization as well as to replace the inutile provision of unfair
competition under Article 189 of the Revised Penal Code. Section 168.3(c) of
the IP Code does not limit the scope of protection on the particular acts
enumerated as it expands the meaning of unfair competition to include "other
acts contrary to good faith of a nature calculated to discredit the goods,
business or services of another." The inherent element of unfair competition is
fraud or deceit, and that hoarding of large quantities of a competitor's empty
bottles is necessarily characterized by bad faith. It claims that its Bicol bottling
operation was prejudiced by the respondents' hoarding and destruction of its
empty bottles.
The petitioner also argues that the quashal of the search warrant was improper
because it complied with all the essential requisites of a valid warrant. The
empty bottles were concealed in Pepsi shells to prevent discovery while they
were systematically being destroyed to hamper the petitioner's bottling
operation and to undermine the capability of its bottling operations in Bicol.
The respondents counter-argue that although Judge Ocampo conducted his
own examination, he gravely erred and abused his discretion when he ignored
the rule on the need of sufficient evidence to establish probable cause;
satisfactory and convincing evidence is essential to hold them guilty of unfair
competition; the hoarding of empty Coke bottles did not cause actual or
probable deception and confusion on the part of the general public; the alleged
criminal acts do not show conduct aimed at deceiving the public; there was no
attempt to use the empty bottles or pass them off as the respondents' goods.
The respondents also argue that the IP Code does not criminalize bottle
hoarding, as the acts penalized must always involve fraud and deceit. The
hoarding does not make them liable for unfair competition as there was no
deception or fraud on the end-users.

THE ISSUE
Based on the parties' positions, the basic issue submitted to us for resolution is
whether the Naga MTC was correct in issuing Search Warrant No. 2001-01 for
the seizure of the empty Coke bottles from Pepsi's yard for probable violation of
Section 168.3 (c) of the IP Code. This basic issue involves two sub-issues,
namely, the substantive issue of whether the application for search warrant
effectively charged an offense, i.e., a violation of Section 168.3 (c) of the IP
Code; and the procedural issue of whether the MTC observed the procedures
required by the Rules of Court in the issuance of search warrants.
OUR RULING
We resolve to deny the petition for lack of merit.
We clarify at the outset that while we agree with the RTC decision, our
agreement is more in the result than in the reasons that supported it. The
decision is correct in nullifying the search warrant because it was issued on an
invalid substantive basis - the acts imputed on the respondents do not violate
Section 168.3 (c) of the IP Code. For this reason, we deny the present petition.
The issuance of a search warrant 10 against a personal property11 is governed by
Rule 126 of the Revised Rules of Court whose relevant sections state:
Section 4. Requisites for issuing search warrant. - A search warrant
shall not issue except uponprobable cause in connection with one
specific offense to be determined personally by the judge after
examination under oath or affirmation of the complainant and the
witnesses he may produce, and particularly describing the place to be
searched and the things to be seized which may be anywhere in the
Philippines.
Section 5. Examination of complainant; record. - The judge must,
before issuing the warrant,personally examine in the form of
searching questions and answers, in writing and under oath, the
complainant and the witnesses he may produce on facts personally
known to them and attach to the record their sworn statements together
with the affidavits submitted.
Section 6. Issuance and form of search warrant. - If the judge is
satisfied of the existence of facts upon which the application is based or
that there is probable cause to believe that they exist, he shall issue the
warrant, which must be substantially in the form prescribed by these
Rules. [Emphasis supplied]

To paraphrase this rule, a search warrant may be issued only if there is


probable cause in connection with a specific offense alleged in an application
based on the personal knowledge of the applicant and his or her witnesses.
This is the substantive requirement in the issuance of a search warrant.
Procedurally, the determination of probable cause is a personal task of the
judge before whom the application for search warrant is filed, as he has to
examine under oath or affirmation the applicant and his or her witnesses in the
form of "searching questions and answers" in writing and under oath. The
warrant, if issued, must particularly describe the place to be searched and the
things to be seized.
We paraphrase these requirements to stress that they have substantive and
procedural aspects. Apparently, the RTC recognized this dual nature of the
requirements and, hence, treated them separately; it approved of the way the
MTC handled the procedural aspects of the issuance of the search warrant but
found its action on the substantive aspect wanting. It therefore resolved to
nullify the warrant, without however expressly declaring that the MTC gravely
abused its discretion when it issued the warrant applied for. The RTC's error,
however, is in the form rather than the substance of the decision as the
nullification of the issued warrant for the reason the RTC gave was equivalent
to the declaration that grave abuse of discretion was committed. In fact, we so
rule as the discussions below will show.
Jurisprudence teaches us that probable cause, as a condition for the issuance
of a search warrant, is such reasons supported by facts and circumstances as
will warrant a cautious man in the belief that his action and the means taken in
prosecuting it are legally just and proper. Probable cause requires facts and
circumstances that would lead a reasonably prudent man to believe that an
offense has been committed and the objects sought in connection with that
offense are in the place to be searched.12 Implicit in this statement is the
recognition that an underlying offense must, in the first place, exist. In other
words, the acts alleged, taken together, must constitute an offense and that
these acts are imputable to an offender in relation with whom a search warrant
is applied for.
In the context of the present case, the question is whether the act charged alleged to be hoarding of empty Coke bottles - constitutes an offense under
Section 168.3 (c) of the IP Code. Section 168 in its entirety states:
SECTION 168. Unfair Competition, Rights, Regulation and Remedies. 168.1. A person who has identified in the mind of the public the goods
he manufactures or deals in, his business or services from those of
others, whether or not a registered mark is employed, has a property
right in the goodwill of the said goods, business or services so

identified, which will be protected in the same manner as other property


rights.

We do not agree with the petitioner's expansive interpretation of Section 168.3


(c).

168.2. Any person who shall employ deception or any other means
contrary to good faith by which he shall pass off the goods
manufactured by him or in which he deals, or his business, or services
for those of the one having established such goodwill, or who shall
commit any acts calculated to produce said result, shall be guilty of
unfair competition, and shall be subject to an action therefor.

"Unfair competition," previously defined in Philippine jurisprudence in relation


with R.A. No. 166 and Articles 188 and 189 of the Revised Penal Code, is now
covered by Section 168 of the IP Code as this Code has expressly repealed
R.A. No. 165 and R.A. No. 166, and Articles 188 and 189 of the Revised Penal
Code.

168.3. In particular, and without in any way limiting the scope of


protection against unfair competition, the following shall be deemed
guilty of unfair competition:
(a) Any person, who is selling his goods and gives them the
general appearance of goods of another manufacturer or
dealer, either as to the goods themselves or in the wrapping of
the packages in which they are contained, or the devices or
words thereon, or in any other feature of their appearance,
which would be likely to influence purchasers to believe that
the goods offered are those of a manufacturer or dealer, other
than the actual manufacturer or dealer, or who otherwise
clothes the goods with such appearance as shall deceive the
public and defraud another of his legitimate trade, or any
subsequent vendor of such goods or any agent of any vendor
engaged in selling such goods with a like purpose;
(b) Any person who by any artifice, or device, or who employs
any other means calculated to induce the false belief that such
person is offering the services of another who has identified
such services in the mind of the public; or
(c) Any person who shall make any false statement in the
course of trade or who shall commit any other act contrary to
good faith of a nature calculated to discredit the goods,
business or services of another.
168.4. The remedies provided by Sections 156, 157 and 161 shall
apply mutatis mutandis. (Sec. 29, R.A. No. 166a)
The petitioner theorizes that the above section does not limit the scope of
protection on the particular acts enumerated as it expands the meaning of
unfair competition to include "other acts contrary to good faith of a nature
calculated to discredit the goods, business or services of another." Allegedly,
the respondents' hoarding of Coca Cola empty bottles is one such act.

Articles 168.1 and 168.2, as quoted above, provide the concept and general
rule on the definition of unfair competition. The law does not thereby
cover every unfair act committed in the course of business; it covers only acts
characterized by "deception or any other means contrary to good faith" in
the passing off of goods and services as those of another who has established
goodwill in relation with these goods or services, or any other act calculated to
produce the same result.
What unfair competition is, is further particularized under Section 168.3 when it
provides specifics of what unfair competition is "without in any way limiting the
scope of protection against unfair competition." Part of these particulars is
provided under Section 168.3(c) which provides the general "catch-all" phrase
that the petitioner cites. Under this phrase, a person shall be guilty of unfair
competition "who shall commit any other act contrary to good faith of a nature
calculated to discredit the goods, business or services of another."
From jurisprudence, unfair competition has been defined as the passing off (or
palming off) or attempting to pass off upon the public the goods or business of
one person as the goods or business of another with the end and probable
effect of deceiving the public. It formulated the "true test" of unfair competition:
whether the acts of defendant are such as are calculated to deceive the
ordinary buyer making his purchases under the ordinary conditions which
prevail in the particular trade to which the controversy relates. 13 One of the
essential requisites in an action to restrain unfair competition is proof of fraud;
the intent to deceive must be shown before the right to recover can exist. 14 The
advent of the IP Code has not significantly changed these rulings as they are
fully in accord with what Section 168 of the Code in its entirety
provides. Deception, passing off and fraud upon the public are still the key
elements that must be present for unfair competition to exist.
The act alleged to violate the petitioner's rights under Section 168.3 (c) is
hoarding which we gather to be the collection of the petitioner's empty bottles
so that they can be withdrawn from circulation and thus impede the circulation
of the petitioner's bottled products. This, according to the petitioner, is an act
contrary to good faith - a conclusion that, if true, is indeed an unfair act on the
part of the respondents. The critical question, however, is not the intrinsic

unfairness of the act of hoarding; what is critical for purposes of Section 168.3
(c) is to determine if the hoarding, as charged, "is of a nature calculated to
discredit the goods, business or services" of the petitioner.
We hold that it is not. Hoarding as defined by the petitioner is not even an act
within the contemplation of the IP Code.

A second test, if a disputed matter does not expressly refer to an intellectual


property right as defined above, is whether it falls under the general "unfair
competition" concept and definition under Sections 168.1 and 168.2 of the
Code. The question then is whether there is "deception" or any other similar act
in "passing off" of goods or services to be those of another who enjoys
established goodwill.

The petitioner's cited basis is a provision of the IP Code, a set of rules that refer
to a very specific subject - intellectual property. Aside from the IP Code's actual
substantive contents (which relate specifically to patents, licensing, trademarks,
trade names, service marks, copyrights, and the protection and infringement of
the intellectual properties that these protective measures embody), the
coverage and intent of the Code is expressly reflected in its "Declaration of
State Policy" which states:

Separately from these tests is the application of the principles of statutory


construction giving particular attention, not so much to the focus of the IP Code
generally, but to the terms of Section 168 in particular. Under the principle of
"noscitur a sociis," when a particular word or phrase is ambiguous in itself or is
equally susceptible of various meanings, its correct construction may be made
clear and specific by considering the company of words in which it is found or
with which it is associated.15

Section 2. Declaration of State Policy. - The State recognizes that an


effective intellectual and industrial property system is vital to the
development of domestic and creative activity, facilitates transfer of
technology, attracts foreign investments, and ensures market access
for our products. It shall protect and secure the exclusive rights of
scientists, inventors, artists and other gifted citizens to their intellectual
property and creations, particularly when beneficial to the people, for
such periods as provided in this Act.

As basis for this interpretative analysis, we note that Section 168.1 speaks of a
person who has earned goodwill with respect to his goods and services and
who is entitled to protection under the Code, with or without a registered
mark. Section 168.2, as previously discussed, refers to the general definition of
unfair competition. Section 168.3, on the other hand, refers to the specific
instances of unfair competition, with Section 168.1 referring to the sale of
goods given the appearance of the goods of another; Section 168.2, to the
inducement of belief that his or her goods or services are that of another who
has earned goodwill; while the disputed Section 168.3 being a "catch all"
clause whose coverage the parties now dispute.

The use of intellectual property bears a social function. To this end, the
State shall promote the diffusion of knowledge and information for the
promotion of national development and progress and the common
good.
It is also the policy of the State to streamline administrative procedures
of registering patents, trademarks and copyright, to liberalize the
registration on the transfer of technology, and to enhance the
enforcement of intellectual property rights in the Philippines. (n)
"Intellectual property rights" have furthermore been defined under Section 4 of
the Code to consist of: a) Copyright and Related Rights; b) Trademarks and
Service Marks; c) Geographic Indications; d) IndustrialDesigns; e) Patents; f)
Layout-Designs (Topographies) of Integrated Circuits; and g)Protection of
Undisclosed Information.
Given the IP Code's specific focus, a first test that should be made when a
question arises on whether a matter is covered by the Code is to ask if it refers
to an intellectual property as defined in the Code. If it does not, then coverage
by the Code may be negated.

Under all the above approaches, we conclude that the "hoarding" - as defined
and charged by the petitioner - does not fall within the coverage of the IP Code
and of Section 168 in particular. It does not relate to any patent, trademark,
trade name or service mark that the respondents have invaded, intruded into or
used without proper authority from the petitioner. Nor are the respondents
alleged to be fraudulently "passing off" their products or services as those of the
petitioner. The respondents are not also alleged to be undertaking any
representation or misrepresentation that would confuse or tend to confuse the
goods of the petitioner with those of the respondents, or vice versa. What in
fact the petitioner alleges is an act foreign to the Code, to the concepts it
embodies and to the acts it regulates; as alleged, hoarding inflicts unfairness by
seeking to limit the opposition's sales by depriving it of the bottles it can use for
these sales.
In this light, hoarding for purposes of destruction is closer to what another law R.A. No. 623 - covers, to wit:
SECTION 1. Persons engaged or licensed to engage in the
manufacture, bottling or selling of soda water, mineral or aerated

waters, cider, milk, cream, or other lawful beverages in bottles, boxes,


casks, kegs, or barrels, and other similar containers, with their names
or the names of their principals or products, or other marks of
ownership stamped or marked thereon, may register with the Philippine
Patent Office a description of the names or are used by them, under
the same conditions, rules, and regulations, made applicable by law or
regulation to the issuance of trademarks.
SECTION 2. It shall be unlawful for any person, without the written
consent of the manufacturer, bottler or seller who has successfully
registered the marks of ownership in accordance with the provisions of
the next preceding section, to fill such bottles, boxes, kegs, barrels,
or other similar containers so marked or stamped, for the purpose
of sale, or to sell, dispose of, buy, or traffic in, or wantonly destroy
the same, whether filled or not, or to use the same for drinking
vessels or glasses or for any other purpose than that registered
by the manufacturer, bottler or seller. Any violation of this section
shall be punished by a fine or not more than one hundred pesos or
imprisonment of not more than thirty days or both.
As its coverage is defined under Section 1, the Act appears to be a measure
that may overlap or be affected by the provisions of Part II of the IP Code on
"The Law on Trademarks, Service Marks and Trade Names." What is certain is
that the IP Code has not expressly repealed this Act. The Act appears, too, to
have specific reference to a special type of registrants - the manufacturers,
bottlers or sellers of soda water, mineral or aerated waters, cider, milk, cream,
or other lawful beverages in bottles, boxes, casks, kegs, or barrels, and other
similar containers - who are given special protection with respect to the
containers they use. In this sense, it is in fact a law of specific coverage and
application, compared with the general terms and application of the IP Code.
Thus, under its Section 2, it speaks specifically of unlawful use of containers
and even of the unlawfulness of their wanton destruction - a matter that
escapes the IP Code's generalities unless linked with the concepts of
"deception" and "passing off" as discussed above.
Unfortunately, the Act is not the law in issue in the present case and one that
the parties did not consider at all in the search warrant application. The
petitioner in fact could not have cited it in its search warrant application since
the "one specific offense" that the law allows and which the petitioner used was
Section 168.3 (c). If it serves any purpose at all in our discussions, it is to show
that the underlying factual situation of the present case is in fact covered by
another law, not by the IP Code that the petitioner cites. Viewed in this light, the
lack of probable cause to support the disputed search warrant at once becomes
apparent.

Where, as in this case, the imputed acts do not violate the cited offense, the
ruling of this Court penned by Mr. Justice Bellosillo is particularly instructive:
In the issuance of search warrants, the Rules of Court requires a
finding of probable cause in connection with one specific offense to be
determined personally by the judge after examination of the
complainant and the witnesses he may produce, and particularly
describing the place to be searched and the things to be seized.
Hence, since there is no crime to speak of, the search warrant
does not even begin to fulfill these stringent requirements and is
therefore defective on its face. The nullity of the warrant renders
moot and academic the other issues raised in petitioners' Motion to
Quash and Motion for Reconsideration. Since the assailed search
warrant is null and void, all property seized by virtue thereof should be
returned to petitioners in accordance with established jurisprudence. 16
Based on the foregoing, we conclude that the RTC correctly ruled that the
petitioner's search warrant should properly be quashed for the petitioner's
failure to show that the acts imputed to the respondents do not violate the cited
offense. There could not have been any probable cause to support the
issuance of a search warrant because no crime in the first place was effectively
charged. This conclusion renders unnecessary any further discussion on
whether the search warrant application properly alleged that the imputed act of
holding Coke empties was in fact a "hoarding" in bad faith aimed to prejudice
the petitioner's operations, or whether the MTC duly complied with the
procedural requirements for the issuance of a search warrant under Rule 126 of
the Rules of Court.
WHEREFORE, we hereby DENY the petition for lack of merit. Accordingly, we
confirm that Search Warrant No. 2001-01, issued by the Municipal Trial Court,
Branch 1, Naga City, is NULL and VOID. Costs against the petitioner.
SO ORDERED.

15

Agpalo, Statutory Construction, 3rd (1995) Ed., at p. 159, citing Co Kim Chan
v. Valdez Tan Keh, 75 Phil 371, and Soriano v. Sandiganbayan, G.R. No.
65952, July 1, 1984, among others.

Noscitur a sociis (A word is known by the company it keeps)


In law, it is a rule of language used by the courts to help interpret in legislation
under which the questionable meaning of a doubtful word can be derived from
its association with other words. Under this rule, statutes should be construed in
light of their context.
Related cases: People vs. Santiago, Coca- Cola Bottlers Philippines vs. Gomez

What is NOSCITUR A SOCIIS?


A latin term for 'it is known by the company it keeps', it is the concept that the
intended meaning of an ambiguous word depends on the context in which it is
used.
Legal maxim that the meaning of an unclear word or phrase is to be determined
(constructed) on the basis of its context the words or phrases surrounding it. As
UK judge J. Stamp put it (in the 1967 case of Bourne vs. Norwich Crematorium
Ltd.), "Sentences are not mere collections of words to be taken out of
the sentence,
defined
separately
by reference to
the dictionary or
decided cases, and then put back into the sentence with the meaning you
haveassigned to them as separate words ...." Latin for, it is known by
the company it keeps.

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