Case Digest (G.R. No. 167866) Core Legal Reasoning Model
Facts:
This case pertains to the complaint filed by respondents Pepe B. Pagdanganan and Pepito A. Lumahan against petitioners Pepsi-Cola Products Philippines, Incorporated (PCPPI) and PEPSICO, Incorporated on December 22, 1992, at the Regional Trial Court (RTC) of Pasig City, Branch 163. The controversy arose from a promotional campaign called "Number Fever," approved by the Department of Trade and Industry (DTI), which began in 1992. This promotion aimed to distribute cash prizes to consumers holding specially marked crowns or resealable caps from Pepsi products, displaying a winning three-digit number, a unique seven-digit alpha-numeric security code, and the designated amount of the prize ranging from ₱1,000.00 to ₱1,000,000.00.
On May 25, 1992, the number "349" was announced as a winning number for the following day. However, when consumers attempted to redeem crowns bearing this winning number that had the incorrect security codes "L-2560-FQ" and &q
Case Digest (G.R. No. 167866) Expanded Legal Reasoning Model
Facts:
- Initiation and Mechanics of the “Number Fever” Promo
- Petitioners Pepsi-Cola Products Philippines, Inc. (PCPPI) and Pepsico, Inc. launched a promotional campaign entitled “Number Fever” in 1992, which was approved and supervised by the Department of Trade and Industry (DTI).
- The promotion involved specially marked crowns and resealable caps of various softdrink products (Pepsi, 7-Up, Mirinda, Mountain Dew) featuring:
- A three-digit number;
- A seven-digit alpha-numeric security code; and
- The cash prize amount (P1,000.00; P10,000.00; P50,000.00; P100,000.00; or P1,000,000.00).
- To determine winning combinations, petitioners engaged D.G. Consultores, a Mexican consultancy experienced in similar promotions, to randomly pre-select winning three-digit numbers and their corresponding security codes from a seeded pool of one thousand three-digit numbers.
- The mechanics required that on designated weekdays from February 17, 1992, until May 8, 1992, a randomly pre-selected winning number was announced through national and local media, with the promise that holders of crowns carrying the winning number would be entitled to the printed cash prize.
- Extension and Subsequent Issues in the Campaign
- Due to the success of the original campaign, petitioners extended “Number Fever” for an additional five weeks until June 12, 1992.
- For the extended period, petitioners again employed D.G. Consultores to select 25 additional winning numbers with their corresponding security codes and artworks.
- On May 25, 1992, the winning three-digit combination “349” was announced for the following day, May 26, 1992.
- Later that night, reports emerged that many attempted to redeem “349” crowns and caps bearing security codes “L-2560-FQ” and “L-3560-FQ.”
- Verification revealed that although the number “349” was indeed selected as a winning combination, the aforementioned security codes did not match the predetermined winning code for “349.”
- Petitioners’ Announcement and Respondents’ Claims
- Petitioners issued a public statement clarifying that only those “349” crowns bearing the correct security codes—as contained in an official master list stored in a bank vault with the DTI—would be redeemed at full prize value.
- As an act of goodwill, petitioners offered to redeem non-winning “349” crowns (those with incorrect security codes) for a reduced amount of P500.00 each until June 12, 1992.
- Despite this announcement, respondent Pepe B. Pagdanganan demanded the cash prize for several “349” crowns (four 7-Up, two Mirinda, and one additional 7-Up crown) totaling significant prize amounts (P1,000,000.00 and P100,000.00), all bearing the disputed security code.
- Similarly, respondent Pepito A. Lumahan claimed his two “winning” crowns (one for P1,000,000.00 and one for P100,000.00) should be honored.
- Petitioners refused to pay the claimed prizes, leading respondents to file a collective complaint for Sum of Money and Damages before the RTC of Pasig City, Branch 163.
- Procedural History and Prior Adjudications
- After trial, the Regional Trial Court (RTC) issued a decision on August 3, 2000, dismissing the complaint but awarding nominal amounts (P3,500.00 to Pagdanganan and P1,000.00 to Lumahan) as goodwill compensation, based on the finding that the winning crown must match with the correct security code contained in the master list.
- Respondents subsequently appealed, and the Court of Appeals, in its February 13, 2004 Decision, reversed the RTC ruling by ordering petitioners to pay P5,000,000.00 to Pagdanganan and P1,200,000.00 to Lumahan.
- Petitioners’ Motion for Reconsideration was denied in the April 26, 2005 Resolution.
- The instant petition for review on certiorari under Rule 45 was then elevated to the Supreme Court, where the issues concerning the proper interpretation of the promo mechanics and the binding nature of prior cases were raised.
Issues:
- Whether or not petitioners are estopped from raising the doctrine of stare decisis in the present case.
- The argument centers on whether the parties may re-litigate issues already settled in prior related cases.
- Whether or not decisions in the cases of Rodrigo, Mendoza, Patan, and De Mesa, despite respondents not being parties therein, are binding precedent.
- The contention involves the applicability of these prior rulings to the current dispute.
- Whether respondents have introduced an issue that was not previously adjudicated in the aforementioned cases.
- Whether or not the Senate and DTI Task Force reports have relevance or are controlling in resolving the issues at hand.
- Whether respondents may seek affirmative relief without having exhausted the administrative or appellate remedies prescribed by the promo’s mechanics.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)