Case Digest (G.R. No. L-19650)
Facts:
Caltex (Philippines) Inc. v. Enrico Palomar, G.R. No. L-19650. September 29, 1966, Supreme Court En Banc, Ruiz Castro, J., writing for the Court.Petitioner Caltex (Philippines) Inc. planned a multi-stage promotional scheme called the "Caltex Hooded Pump Contest" that invited "motor vehicle owners and/or licensed drivers" (excluding Caltex employees, dealers and their immediate families) to estimate the liters a hooded pump would dispense during a fixed period. Participation required no purchase, fee, or other consideration; entry forms were available on demand at Caltex stations and deposited in sealed cans. Winners were to be selected at dealer, regional and national levels with merchandise and cash prizes (including a P3,000 first prize at national level) and travel for regional first-prize winners.
Before conducting the promotion, Caltex sought advance clearance from the postal authorities under the Postal Law (Revised Administrative Code, particularly Secs. 1954(a), 1982 and 1983) by letter dated October 31, 1960 enclosing the contest rules. The Acting Postmaster General refused clearance, relying in part on Opinion 217 (Series 1953) of the Secretary of Justice and maintained that the scheme either involved "consideration" (thus a lottery) or was a prohibited "gift enterprise"; he warned that a fraud order would be issued should the contest be conducted.
Caltex filed a petition for declaratory relief in the trial court seeking a judicial declaration that the contest did not violate the Postal Law and ordering respondent to allow use of the mails to publicize the contest. The trial court ruled for Caltex, declaring the contest not violative of the Postal Law and that the Postmaster General had no right to bar distribution by mail. The Postmaster General appealed the trial court ...(Pro-only)
Issues:
- Does the petition state a sufficient cause of action for declaratory relief?
- Does the "Caltex Hooded Pump Contest" violate the Postal Law (Revised Administrative Code, Secs. 1954(a), 1982, 1983) as a lottery, gift enterprise, or similar no...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)