The Mangling of Rights in Philippine Broadcasting

BROADCASTING DEFINED

Broadcasting is defined in the Philippine IP Code as the transmission by wireless means for the public reception of sounds or of images or of representations thereof; such transmission by satellite is also "broadcasting" where the means for decrypting are provided to the public by the broadcasting organization or with its consent; (IP Code, Section 202.7)

Under this setup, the broadcaster has the exclusive right to carry out, authorize or prevent any of the following acts:

1. The rebroadcasting of their broadcasts
2. The recording in any manner, including the making of films or the use of video tape, of their broadcasts for the purpose of communication to the public of television broadcasts of the same; and
3. The use of such records for fresh transmissions or for fresh recording. (IP Code, Section 211)

THE CURIOUS CASE OF ABS-CBN v. PMSI

In 2009, the Supreme Court decided on a case called ABS-CBN Broadcasting Corp. v. Philippine Multimedia System, Inc., G.R. Nos. 175769-70 and I found it to be a disturbing read.

In this case, ABS-CBN, a Philippine broadcaster sued the company, Philippine Multimedia System, Inc. (PMSI) that ran Dream Satellite TV for making ABS-CBN channels available to its subscribers without permission.

ABS-CBN won the case at the Bureau of Legal Affairs (BLA) of the Intellectual Property Office (IPO) and was able to acquire a temporary restraining order against Dream Satellite TV.

The case would be appealed to the Director General, reversed the ruling that would later be affirmed by the Court of Appeals (CA) and the Supreme Court (SC).

Ultimately, the court decided that PMSI may ignore the intellectual property rights of ABS-CBN because PMSI's legislative franchise (Republic Act No. 8630) and a Memorandum Circular mandated it to carry local channels, including those owned by ABS-CBN. (Although the law never expressly exempted PMSI from acquiring licenses from the broadcasters)

WORST STATEMENT EVER

I can't believe I read this paragraph from the case:

Relevantly, PMSI’s carriage of Channels 2 and 23 is material in arriving at the ratings and audience share of ABS-CBN and its programs. These ratings help commercial advertisers and producers decide whether to buy airtime from the network. Thus, the must-carry rule is actually advantageous to the broadcasting networks because it provides them with increased viewership which attracts commercial advertisers and producers.

Like asking a musician to play for free in front of a bar’s paying customers because it’s good for exposure… familiar?

PUBLIC WELFARE IS GREATER THAN PROPERTY RIGHTS, BUT...

Indeed, I must agree with the observation of the court that “… the welfare of the people must not be sacrificed in the pursuit of profit.”

After all, the Philippine Constitution makes it clear that:

The use of property bears a social function, and all economic agents shall contribute to the common good. Individuals and private groups, including corporations, cooperatives, and similar collective organizations, shall have the right to own, establish, and operate economic enterprises, subject to the duty of the State to promote distributive justice and to intervene when the common good so demands. (1987 Constitution, Article XII, Section 6)

BUT it is also true that the State has the responsibility of providing just compensation if and when it decides to use or take private property for a public purpose. Taking the intellectual property of ABS-CBN and handing it over to Dream Satellite TV as part of their business without a license is nothing short of a violation of the Constitutional right to due process:

No person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied the equal protection of the laws. (1987 Constitution, Article III, Section 1)

COPYRIGHT AND RELATED RIGHTS OF OTHER PERSONS AFFECTED

In every broadcast, there are numerous copyrights attached to the content, belonging to different persons. Copyright belongs to the writers who wrote the scripts, the designers of the program, the graphic artists, writers of the music, the filmmakers, the photographers and videographers, the set and costume designers and all those creative persons who were involved in creating the content. 

Similarly, there are also related rights that belong to the producers and performers of the sound recordings used for the TV programs. 

Any observer must remember that the simple act of making the content available to the public without the consent of the creators is a violation of copyright law and the rights of many individuals and organizations.

SUPREME COURT SHOULD HAVES...

The court might have arrived at a more instructive and precise decision if it took the following steps:

1. Ruled on the constitutionality of the ‘must-carry’ rule of PMSI’s legislative franchise and the related Memorandum Order (which would have shown that the rule was confiscatory and in violation of the due process); 
2. Done a fair use analysis in favor of the copyright holders (PMSI’s use would have failed the fair use test); 
3. Examined the legislative franchise of ABS-CBN and see if it has the obligation to provide its content to satellite TV providers without a license. (Upon examination of R.A. 7966, there is no such obligation); and
4. Harmonized the IP Code with PMSI’s legislative franchise instead of presuming that the latter was an exception to the former.

A DECISION BAD FOR BUSINESS

There was simply a misunderstanding of copyright and related rights and their role in business. We are now left with a situation of self-discrimination where Filipino broadcast organizations are not paid for the use of their content by cable and satellite TV providers while foreign broadcasters are properly paid for theirs. 

Copyright and related rights over broadcasts have fallen off the balance in this country. I think with better IP education for judges, business organizations and lawmakers, it would still be possible to salvage this situation for better times.

Intellectual Property Rights in the Bangsamoro

Trivia: Did you know that intellectual property rights are mentioned in the Draft Bill Creating the Bangsamoro sub-state in Mindanao?

According Article V of the bill, intellectual property rights are categorized as one of the reserved powers of the Central Philippine Government. They found it wise to leave the management of this highly technical matter to the national government. 

This means that you won't be hearing of a Bangsamoro Intellectual Property Office in the near future. 

Nonetheless, I do hope the IPO sets up a regional office for the Bangsamoro because if and when the region is created, we should expect a whole lot of new businesses to come in.

When there is peace, there is greater room for art, beauty, discovery and exploration.

Quick, What is a Trademark?

CREATIVE STATE - Does the Government have Copyright?

A client from last week raised several questions about government copyright. Working as the head of the publications unit of a government office and was worried about how Philippine copyright law would affect her work.

This is a deeper analysis of what I explained to her during our consultation, which I hope will be of use to other government institutions. With better IP education, I know government offices will be able to create better contracts and maximize benefits from the use their creative work.

DEFINITION

The Intellectual Property Code of the Philippines (IP Code, R.A. 8293) defines Work of the Government of the Philippines as a

work created by an officer or employee of the Philippine Government or any of its subdivisions and instrumentalities, including government-owned or -controlled corporations as a part of his regularly prescribed official duties. (Section 171.11) 

This definition requires two things: 

1. The creator of the work has to be a government employee or officer; and 

2. The work is created as part of one’s official duties.

When these two conditions above are met, the work automatically becomes unprotected work under Section 176, which reads:  

SEC. 176. Works of the Government. – 176.1. No copyright shall subsist in any work of the Government of the Philippines. However, prior approval of the government agency or office wherein the work is created shall be necessary for exploitation of such work for profit. Such agency or office may, among other things, impose as a condition the payment of royalties. No prior approval or conditions shall be required 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.   

176.2. The author of speeches, lectures, sermons, addresses, and dissertations mentioned in the preceding paragraphs shall have the exclusive right of making a collection of his works.    

176.3. Notwithstanding the foregoing provisions, the Government is not precluded from receiving and holding copyrights transferred to it by assignment, bequest or otherwise; nor shall publication or republication by the Government in a public document of any work in which copyright is subsisting be taken to cause any abridgment or annulment of the copyright or to authorize any use or appropriation of such work without the consent of the copyright owner. 

EXCEPTIONS

So, from cross-referencing the provisions above, it would be safe to say that the general rule is that the Philippine Government cannot acquire copyright by creating original works. 

Having said this, there are some exceptions to the ‘no government copyright rule’: 

1. If the creator of the work is merely a consultant working under a government contract, copyright will arise from his or her original creations. 

e.g. If the Civil Service Commission engages a research team from the University of Sto. Tomas to do a study on ‘The Negative Effects of Social Media on Productivity in Government’, the research team will gain copyright by creation, even if the study is initiated by government. 

2. If the creator does original creative work outside his or her official duties, he or she has copyright over the work. 

e.g. Supposing one is an attorney who works for a politician and the former has the habit of taking photos of his boss’s public activities with his phone camera. The attorney, not being employed as a photographer, gains copyright over his photos by original creation. 

3. The government may acquire copyright from third persons, through assignment, donation and even succession (if the government is the sole heir). In fact, when a government agency hires consultants, the terms of the contract will dictate who shall own the copyright. It may be retained by the consultant or assigned to the government agency. Thus, the government may acquire copyright by other modes, even if may not do so by original creation. 

e.g. If the National Commission for Culture and the Arts (NCCA) conducts an visual arts competition, it may impose a condition that the artists execute a contract assigning copyright to NCCA as a condition for their participation. NCCA will thus acquire copyright by assignment. 

PUBLIC RIGHTS v. PRIVATE RIGHTS

So what is consequence of having a government that generally does not have copyright over its works? 

The answer depends on the kind of government work you are dealing with. Even without copyright, the law affords less-than-copyright protections in certain situations. The term ‘unprotected works’ is actually a misnomer. Take note of the following situations you find yourself in: 

1. In the case of statutes, rules and regulations, the public is free to use them for any purpose. 

2. In the case of 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 the public is free to use them for any purpose except to make a collection or compilation of works from a particular author because that right exclusively belongs to that author. 

3. In the case of other works not included above, prior approval from the government is required before any person can use them for profit. As a condition for such approval, the government may require the payment of royalties. 

Copyright in government can be quite complicated in the Philippines especially when most agencies are not well informed about how to manage their intellectual property. Schools and universities come up with research material regularly. Government radio and TV stations generate content everyday. In the natural course of business, government agencies create incredible volumes of original and derivative material all the time. 

Perhaps things could be easier if the  law simply granted copyright to the government like in other States. Then again, our lawmakers may have observed that there is a public interest angle in keeping some government works in the public domain. As taxpayers, we collectively own many of the public works created and they should be shared to and by the public without being slowed down by copyright claims. 

As in every other case, one must balance intellectual property rights with public interest. 

Photo Blog - NBDB Copyright Clinic on March 28, 2015

Work I actually don't mind giving up my Saturdays for.  

National Book Development Board (NBDB) Copyright Clinic
March 28, 2015
NBDB Office, Ortigas, Pasig City
Organized by NBDB and FILCOLS

How to Make a Living from Music in the Philippines

Last week, I participated in a WIPO-IPOPHL seminar on 'How to Make a Living from Music'.

The key lecturer was Mr. David Stopps, author of the book with the same title. Stopps has had a long experience in music management in the UK, having worked with some of very best acts in the world like U2, the Police and David Bowie among many others.

What Stopps discussed were both familiar and new. Conceptually, I had been trained to understand copyright and collective management to the closest detail. But Stopps was able drive the nail home by talking about his real life experiences and how he witnessed independent artists earn income in so many different ways, as long as intellectual property was respected and complied with. 

Stopps discussed how music is placed in advertisements, films, TV shows, video games, apps and others, earning royalty income for the artist and the producer. He also talked about making derivate income from selling merchandise and product placement during shows. 

This was very interesting stuff that reminded me of how much time and sacrifice we need to put in to elevate the Philippine music business up to that level. 

Mark Thursday Alciso of the Filipino Society of Composers, Authors and Publishers, Inc. (FILSCAP) talked about collective management of copyright and the challenges faced, including the unwillingness of businesses to pay license fees and the confusion caused by having several different organizations collect license fees for different rights over the same music.

Royalty collection also gets harder when one has to deal with large networks or organizations that have a ton of leverage. Artists in the Philippines almost never get paid for the use of their music in films, TV shows or advertisement, a common practice in more developed economies. What ought to be a significant source of income is reduced to zero and a shallow promise of 'artist exposure'... something they would get anyway whether or not they're paid.

Many other concerns were raised like the massive competition we get from foreign acts, the lack of radio airplay and the proliferation of substandard music in the mass market. 

In the end, we find ourselves back where we started. If we want this country to be a source of and a hub for great music, we need to make real changes in our understanding and respect for intellectual property and business. No more pushovers. No more compromise. As artists, we mean business.

_____

For those who missed the seminar, you may still benefit from David Stopp's experience by reading his book, published by the World Intellectual Property Organization (WIPO):

Download the PDF version of David's book from the WIPO Website

Photo Blog - WIPO Seminar on How to Make a Living from Music on July 23 to 24, 2013

I've attended and conducted over a hundred IP Seminars by WIPO in the past four years... but this one was the very best so far.

Glad to be joined by musicians and producers from the mainstream industry as well as the independent sector.

WIPO Seminar on How to Make a Living from Music

July 23 to 24, 2013

Dusit Thani Hotel, Makati City, Philippines

Organized by IPOPHL and WIPO

School-branded Money

Good education is good business.

Trademark Infringement - Jollibean

from www.jollibean.com

Yes, Singapore copies too.

I don't know the real story... whether Jollibee has ever tried to sue or whether they can even win this case.

This can certainly be an interesting debate about protecting well-known Filipino marks. 

If Jollibee can't be protected as THE well-known mark, then all others might as well be lost in overseas commerce.

Have a cup of Jollibean while you think about it...

from www.jollibean.com

Copyright and Trademark Infringement - Diner Dash Bar & Restaurant

Copyright & Trademark Infringement in One Strike

spotted along Bayani Road, Taguig City, Philippines

Trademark Infringement - Shangri-La Restaurant

Shangri-La Restaurant in Times Street, Quezon City, Philippines

From the trademark-junkie favorite Shangri-La International v. Developers Group (G.R. 159931, March 31, 2006 and January 22, 2007) case. 

_____

Read the two Shangri-La cases in the Philippine Supreme Court here:

first case:

http://www.lawphil.net/judjuris/juri2006/mar2006/gr_159938_2006.html

second case:

http://www.lawphil.net/judjuris/juri2007/jan2007/gr_159938_2007.html

Philippine Jurisprudence - The Skechers Trademark Case (2011)

Skechers, USA, Inc. v. Inter Pacific Industrial Trading Corp.

G.R. No. 164321 (2011)

Skechers, USA Inc. is the owner of the registered trademarks “Skechers” and “S within an oval logo”.

Skechers filed a criminal case for trademark infringement against several store-owners that were selling shoes branded as “Strong” and bearing a similar “S” logo. The Regional Trial Court (RTC)  issued search warrants, allowing the National Bureau of Investigation (NBI) to raid the stores and confiscate 6,000 pairs of shoes.

The accused moved to quash the warrants, saying that there was no confusing similarity between the “Skechers” and the “Strong” brands.

The RTC granted the motion to quash and ordered the NBI to return the seized goods. The court said that the two brands had glaring differences and that an ordinary prudent consumer would not mistake one for the other.

On certiorari, the Court of Appeals (CA) affirmed the RTC ruling.

The matter was elevated to the Supreme Court (SC).

Issue: Did the accused commit trademark infringement?

Yes, the accused is guilty of trademark infringement.

Under the IP Code (RA No. 8293), trademark infringement is committed when: 

Remedies; Infringement. — Any person who shall, without the consent of the owner of the registered mark:  

155.1. Use in commerce any reproduction, counterfeit, copy, or colorable imitation of a registered mark or the same container or a dominant feature thereof in connection with the sale, offering for sale, distribution, advertising of any goods or services including other preparatory steps necessary to carry out the sale of any goods or services on or in connection with which such use is likely to cause confusion, or to cause mistake, or to deceive; or  

155.2. Reproduce, counterfeit, copy or colorably imitate a registered mark or a dominant feature thereof and apply such reproduction, counterfeit, copy or colorable imitation to labels, signs, prints, packages, wrappers, receptacles or advertisements intended to be used in commerce upon or in connection with the sale, offering for sale, distribution, or advertising of goods or services on or in connection with which such use is likely to cause confusion, or to cause mistake, or to deceive, shall be liable in a civil action for infringement by the registrant for the remedies hereinafter set forth: Provided, That the infringement takes place at the moment any of the acts stated in Subsection 155.1 or this subsection are committed regardless of whether there is actual sale of goods or services using the infringing material. (emphasis supplied)

There is trademark infringement when the second mark used is likely to cause confusion. There are two tests to determine this:

1. Dominancy Test – the court focuses on the similarity of the dominant features of the marks that might cause confusion in the mind of the consumer. Duplication or imitation is not necessary. Even accidental confusion may be cause for trademark infringement. More consideration is given to the aural and visual impressions created by the marks on the buyers and less weight is given to factors like price, quality, sales outlets and market segments.  

Applied to this case: The SC found that the use of the “S” symbol by Strong rubber shoes infringes on the registered Skechers trademark. It is the most dominant feature of the mark -- one that catches the buyer’s eye first. Even if the accused claims that there was a difference because the “S” used by Skechers is found inside an oval, the fact that the accused used the dominant “S” symbol already constitutes trademark infringement.  

The SC disagreed with the CA reasoning that the “S” symbol is already used for many things, including the Superman symbol. Even if this is true, the fact that Strong used same stylized “S” symbol as that of the Skechers brand makes this a case of trademark infringement. The same font and style was used in this case. The Superman “S” symbol is clearly different from the “S” in this case.  

2. Holistic or Totality Test – the court looks at the entirety of the marks as applied to the products, including the labels and packaging. You must not only look at the dominant features but all other features appearing on both marks.  

Applied to this case: Both RTC and CA used the Holistic Test to rule that there was no infringement. Both courts argued the following differences: 

• The mark “S” found in Strong Shoes is not enclosed in an “oval design.”

• The word “Strong” is conspicuously placed at the backside and insoles.

• The hang tags and labels attached to the shoes bears the word “Strong” for respondent and “Skechers U.S.A.” for private complainant;

• Strong shoes are modestly priced compared to the costs of Skechers Shoes.
 

Also using the Holistic Test, the SC corrected the lower courts and ruled that the striking similarities between the products outweigh the differences argued by the respondents:

• Same color scheme of blue, white and gray;

• Same wave-like pattern on the midsole and the outer sole;

• Same elongated designs at the side of the midsole near the heel;

• Same number of ridges on the outer soles (five at the back and six in front);

• Same location of the stylized “S” symbol;

• The words "Skechers Sport Trail" at the back of the Skechers shoes and "Strong Sport Trail" at the back of the Strong shoes, using the same font, color, size, direction and orientation;

• Same two grayish-white semi-transparent circles on top of the heel collars.

The features and overall design of the two products are so similar that there is a high likelihood of confusion. 

Two products do not need to be identical, they just need to be similar enough to confuse the ordinary buyer in order to constitute trademark infringement (Converse Rubber Corporation v. Jacinto Rubber & Plastic Co., 186 Phil. 85 [1980]). Also, the difference in price cannot be a defense in a case for trademark infringement (McDonald’s Corporation v. L.C. Big Mak Burger, Inc., 480 Phil. 402, 434 [2004]).

There are two types of confusion:

1. Product Confusion – where the ordinary prudent purchaser would be induced to purchase on product in the belief that he was buying another.
2. Source or Origin Confusion – although the goods are different, the use of the mark causes the consumer to assume that both products originate from the same source. 

Trademark law protects the owner not only from product confusion but also from source confusion. Protection is not limited to the same or similar products but extends to all cases where:

• The consumer is misled into thinking that the trademark owner extended his business into a new field;

• The consumer is misled into thinking that the trademark owner is in any way connected to the infringer’s activities; or 

• The infringement forestalls the normal potential expansion of the trademark owner’s business.

Trademark law does not only protect the owner’s reputation and goodwill, it also protects the consumers from fraud and confusion. 

In this case, it is clear that there was an attempt to copy the trademark owner’s mark and product design. In trademark infringement cases, you do not need to copy another's mark or product exactly. Colorable imitation is enough.

Is Copyright a Human Right?

Some writers are convinced that copyright is merely a statutory benefit -- that is, it cannot exist without the law.

Like many writers from Europe, however, I subscribe to the old world philosophy that copyright is a human right -- that it transcends business interests and embraces the sacred relationship between the creator and the creation -- the author and the work.

Although domestic laws and treaties do contain provisions on protecting intellectual property, they cannot be considered the ultimate source of these rights. They do not arise from agreements or legislation, but from human nature as creator.

Two important pieces of international law articulate this philosophy:

1. Article 27 (2) of The Universal Declaration of Human Rights (UDHR), known to be the document of authority for human rights, reads: 

Everyone has the right to protection of the moral and material interests resulting from any scientific, literary or artistic production of which he is the author;

2. Article 15 (1) of The United Nations Covenant on Economic, Social and Cultural Rights (UNCESCR) also reads: 

The State Parties to the present Covenant recognize the right of everyone to benefit from the protection of the moral and material interests resulting from any scientific, literary or artistic production of which he is the author.

Like any other person of any other profession, artists, authors and scientists deserve to make a living from their talents. More importantly, they must be acknowledged as the creators of their work. 

So is copyright a human right? To give a yes or no answer to the issue of would be a serious oversimplication that ignores the history and philosophy behind copyright.

The right answer would have to be "partially" -- copyright is partially a human right. At least in the Philippine legal system, it has to be understood this way. Why? Because our law fuses (or confuses) the concept of copyright in the civil law and the common law sense.

Civil law traditions treat copyright or author's rights (droit d'auteur to the French; Urheberrecht to the Germans) as a sacred bond between the author and the work. These rights form what we call in the Philippine IP Code as moral rights. Moral rights, particularly the right of paternity, ought to last forever (e.g. William Shakespeare's authorship to Hamlet will never expire by mere passage of time). 

This is the part of copyright which I am inclined to declare as a human right -- the right of paternity. Like any other human right, it is imprescriptible, inherent, inalienable and universal. Authorship therefore must be likened to a status rather than a right. For a right often disappears after the death of the owner while a status of paternity lasts forever.

So what is the right of Paternity? Section 193.1 of the Philippine IP Code describes it as 

the right to require that the authorship of the works be attributed to him, in particular, the right that his name, as far as practicable, be indicated in a prominent way on the copies, and in connection with the public use of his work 

The old intellectual property law (PD 49) correctly declared that the right of paternity lasts forever. The new law downgraded the right to last only for as long as the economic rights (generally the author's lifetime plus 50 years). This is unacceptable because it limits that part of copyright that is a human right. Today, a bill is being discussed in the Philippine House of Representatives to revert back to the old rule. I hope that the fruit of these discussions finds its way into law very soon.

Common law traditions, on the other hand, tend to focus on the economic benefits of copyright and how it can be used to generate wealth. In Philippine law, these are called economic rights. Economic rights necessarily last only for a certain period of time because they are only statutory grants used to secure a return on investment plus profits for the creator of a work and his or her heirs. 

This is the part of copyright that I consider merely a temporary grant by law, which may be removed or suspended for a greater public purpose. They are not imprescriptible, inherent, inalienable or universal. They, therefore, do not possess the essential characteristics of human rights. 

So here we have the Philippine copyright system. By way of Spain, we carry the long-standing traditions of civil law going back to the Roman Empire -- a philosophy which treats authorship with unique but well-deserved reverence. By way of America, we carry enterprising prowess of the common law tradition -- a philosophy grounded more on giving each creator a livelihood and a chance at survival. And somewhere in the middle of all this, we find ourselves still trying to figure out what to do with our inexhaustible creativity and how it can lift us up to better places. 

For now, we can rest better knowing that we do possess human rights as creators... Partially.

_____

For further reading:

See Mark Robert A. Dy, Teach the World to Sing: Restructuring Philippine Copyright Law under a Regime of Free Expression and Culture (2009) (unpublished J.D. Thesis, Ateneo de Manila University School of Law) (on file with the Ateneo Professional Schools Library). 

The Cool and Creative Pol Medina, Jr.

To become truly great, one has to stand with people, not above them.

- CHARLES DE MONTESQUIEU

In this world of greed and inflated egos, this is a story that must be told so that we might remember that there are still wonderful people out there... that there are still gestures of greatness, no matter how seemingly simple for the originator.

This week, some people from work and I were doing the final edit of a WIPO Copyright Book. We wanted to "Filipinize" the book by changing the examples to suit Filipino culture and experience.

One of the examples in the book was a comic strip by a famous American cartoonist. We wanted to transform the page, and one thing instantly came to mind: Pugad Baboy by Pol Medina, Jr.

I was hesitant at first in asking Mr. Medina for permission to use one of his book covers for the publication. Nevertheless, we sent him an email and formally asked for his permission.

He replied and said "yes" immediately. We were ecstatic. 

And so that was that... or so we thought... 

Three hours later another email arrives... and lo and behold... Mr. Pol Medina, Jr. sent us a strip specially customized for IP Philippines.

This was so much more than we could ask for. He was able to sum up in four boxes what the office has been trying to do for many decades.

Medina is one of the biggest names, if not the biggest, in the industry. He reportedly earns five figures each day for a single strip on the Philippine Daily Inquirer... and yet, with this single stroke, he obliterated the mystique that surrounded his person and his empire... his generosity and humility is something that just gives me goosebumps each time I think about it.

We don't need to save lives to be great. We don't need die as martyrs or run for president to be remembered forever.

Sometimes, doing what you do every single day generously and with a humble heart is enough. This time, it truly was.

Mabuhay ka, Pol Medina, Jr.! Mabuhay ang Pugad Baboy!

To know more about the cartoon, see:
http://en.wikipedia.org/wiki/Pugad_Baboy