Case Digest (G.R. No. 153063-70) Core Legal Reasoning Model
Facts:
The case involves petitioners Amelia D. De Mesa, Araceli Adato, Rodrigo Alvaran, Aida Castro, Baltazar Estrelles, Antonio A. Ferrer, Danilo Garcia, Julio M. Gonzales, Marrieta A. Jose, Pepita Juntado, Eduardo U. Lago, Nestor Roda, Jaime Sanchez, and Juanita Sanchez as they contest the ruling of the Regional Trial Court (RTC) of Makati City, Branch 142, dated April 18, 2002. The RTC dismissed their complaints filed against Pepsi Cola Products Philippines, Inc. (PCPPI) and Pepsico, Inc. based on the principle of stare decisis. The facts of the case are rooted in the “Number Fever” promotional campaign initiated by the respondents where certain bottle caps indicated winning numbers. Petitioners held caps with the number "349," which were announced as a winning number for a contest on May 25, 1992. However, it was later disclosed that there were issues with the security code associated with that number, and holders were not compensated as winning participants. Consequentl
Case Digest (G.R. No. 153063-70) Expanded Legal Reasoning Model
Facts:
- Background of the Promotion
- Petitioners held soft drink bottle caps bearing the number "349," which were purportedly winning crowns in a promotional contest.
- The contest, dubbed "Number Fever," was sponsored by respondents Pepsi Cola Products Philippines, Inc. (PCPPI) and PEPSICO, Inc. (PI).
- Respondent PCPPI is a domestic corporation involved in the production, bottling, and distribution of carbonated drinks, while respondent PI is a foreign corporation licensed to do business in the Philippines and is the major stockholder of PCPPI.
- Selection Process and Implementation
- D.G. Consultores, a Mexican consulting firm experienced in handling similar promotions abroad, was tasked with randomly pre-selecting the winning numbers and their corresponding security codes.
- The selection process was implemented with the approval of the Department of Trade and Industry (DTI).
- During the initial promotional period (February 17 to May 8, 1992), respondents seeded 1,000 numbers comprising:
- 60 winning numbers
- 510 non-winning numbers
- 430 numbers left unused
- To safeguard the integrity of the list, the DTI required that the winning numbers and corresponding security codes be deposited in a bank safety deposit box.
- Extension and Subsequent Developments
- Due to the campaign’s success, respondents extended the promotion for an additional five weeks (May 10 to June 12, 1992).
- D.G. Consultores was again commissioned to select 25 additional winning numbers from the unused ones.
- On May 25, 1992, the number "349" was announced as the winning number for the May 26 draw.
- Later that same night, an error was discovered when PCPPI’s Marketing Services Manager, Quintin Gomez, Jr., notified DTI Director Madarang about possible security code discrepancies linked to the announcement.
- Resulting Litigation and Related Cases
- Numerous holders of the allegedly winning "349" crowns were not paid, leading to the filing of several separate complaints seeking specific performance and damages.
- Separate cases evolved:
- Civil Case No. 93-68351 in the RTC of Manila, Branch 16 (later withdrawn by some plaintiffs, leaving Gerson Mendoza as the sole plaintiff in one case).
- Romulo Rodrigo, et al. v. Pepsi Cola Products Philippines, Inc., et al. (Civil Case No. 94-71403) filed at the RTC of Manila, Branch 50.
- The petitioners filed their own separate complaints in Civil Cases Nos. 94-2414 to 94-2421 before the RTC of Makati City, Branch 142.
- The RTC eventually dismissed the complaints in both the Mendoza and Rodrigo cases.
- In the Mendoza case, the RTC dismissed the complaint which was later upheld by the Court of Appeals and a petition for review was denied by the Supreme Court.
- Similarly, in the Rodrigo case, the dismissal by the RTC was affirmed by the Court of Appeals and subsequent petitions for review and reconsideration were likewise denied.
- On December 11, 2000, petitioners filed a motion with the RTC to either adopt the evidence from the Mendoza and Rodrigo cases or to archive the present case pending the final resolution of those cases, which the RTC granted on January 8, 2001.
- After the Rodrigo case became final and executory on February 5, 2002, respondents moved to dismiss the complaints in the pending case based on the principle of stare decisis, leading to the RTC's order for dismissal.
Issues:
- Applicability of Res Judicata and Stare Decisis
- Whether the present petition is barred by the doctrine of res judicata given that the facts, evidence, and legal issues are identical to those already decided in the Mendoza and Rodrigo cases.
- Whether the principle of stare decisis, which mandates the adherence to established judicial decisions, precludes re-litigation of the matter in the present case.
- Identity of Parties and Prematurity of Dismissal
- Petitioners contend that there is no complete identity of parties, arguing that res judicata should not apply.
- Petitioners argue that the dismissal of their complaint was premature since their motion to archive was conditioned on the final resolution of related cases and that further review on the merits is warranted.
- Interpretation of the Winning Combination
- Petitioners assert that the security code determining the winning crowns was misinterpreted in the earlier decisions, making another review necessary.
- They further claim that a breached contractual obligation should compel respondents to perform, regardless of prior rulings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)