Case Digest (G.R. No. 228505)
Facts:
The Philippine Racing Commission and the Games and Amusements Board, petitioners, v. Manila Jockey Club, Inc., respondent, G.R. No. 228505, June 16, 2021, the Supreme Court Third Division, Delos Santos, J., writing for the Court. Petitioners sought review of the July 27, 2016 Order of the Regional Trial Court (RTC) of Bacoor, Cavite, Branch 19, which granted respondent MJCI’s April 5, 2016 Motion for Summary Judgment, and the RTC’s November 22, 2016 Order denying petitioners’ Motion for Reconsideration.Manila Jockey Club, Inc. (MJCI) is a corporation (incorporated 1939) granted an original franchise under R.A. 6631 and an extended franchise under R.A. 8407 (approved November 23, 1997) to construct and operate a racetrack and to conduct horse races with betting. P.D. 420 (March 20, 1974) created PHILRACOM, vesting it with “exclusive jurisdiction and control over every aspect of the conduct of horse-racing,” and it enumerated specific powers in Sections 8–10. PHILRACOM promulgated administrative rules, including PR 58‑D (as amended) and Resolution No. 38‑12 (Series of 2012), prescribing that unclaimed dividends be collected within 20 working days and thereafter be allocated 40% to augment prize money, 30% for marketing, and 30% for charitable purposes under PHILRACOM’s control.
MJCI’s betting tickets contain a dorsal notice stating that winning tickets must be claimed within thirty (30) days from date of purchase or the prize will be forfeited in favor of the corporation. MJCI contended that unclaimed dividends are not among the funds remitted to government agencies under R.A. 8407 and therefore are private funds belonging to MJCI; PHILRACOM maintained that PR 58‑D falls within its rule‑making power under P.D. 420 to govern the disposition of unclaimed dividends.
Because of the dispute, MJCI filed a Petition for Declaratory Relief with the RTC of Bacoor on November 7, 2013. Petitioners filed a joint Comment and later an Ad Cautelam Comment asserting that MJCI had already violated PR 58‑D and Resolution No. 38‑12 by retaining unclaimed dividends, and thus declaratory relief was not appropriate. On April 5, 2016 MJCI moved for summary judgment contending only questions of law remained. The RTC granted summary judgment for MJCI on July 27, 2016, declaring PR 58‑D and...(Pro-only)
Issues:
- Was the grant of summary judgment by the RTC proper?
- Did PHILRACOM have statutory rule‑making authority to promulgate PR 58‑D and Resolution No. 38‑12 concerning the disposition of unclaimed dividends?
- Is the condition printed on MJCI’s tickets — that winning tickets not claimed within 30 days are forfeited to MJCI — void as c...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)