Case Digest (G.R. No. 163553) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Yun Kwan Byung v. Philippine Amusement and Gaming Corporation, decided on December 11, 2009 under G.R. No. 163553, the petitioner, a Korean national named Yun Kwan Byung, alleged that during four visits from November 1996 to March 1997 to Casino Filipino Silahis at the Grand Boulevard Hotel in Manila, he accumulated gambling chips worth US$2.1 million under PAGCOR’s Foreign Highroller Marketing Program administered through a “Junket Agreement” dated April 25, 1996 with Korea‐based ABS Corporation. Under this agreement, PAGCOR supplied ABS Corporation with distinctive “junket chips,” and ABS Corporation alone was responsible for collecting losing chips, paying winnings, and settling accounts. Petitioner contended that PAGCOR employees initially redeemed his chips but later refused, prompting him to file a complaint before the Regional Trial Court (RTC) of Manila, Branch 13, seeking redemption of the chips. PAGCOR defended that the chips were issued under the void Junket Agreem Case Digest (G.R. No. 163553) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Yun Kwan Byung (petitioner), a Korean national, played high‐stakes gambling at Casino Filipino in Manila between November 1996 and March 1997.
- Philippine Amusement and Gaming Corporation (PAGCOR) is a government‐owned corporation created by Presidential Decree No. 1869 to operate casinos and generate revenue.
- Junket Agreement with ABS Corporation
- On April 25, 1996, PAGCOR and Korean‐based ABS Corporation executed a “Junket Agreement,” under which PAGCOR:
- Provided ABS with distinct junket chips;
- Agreed that ABS would account for and pay its players’ winnings and losses;
- Reserved a 12.5% share of ABS’s gross winnings or USD 1.5 million over six months.
- Petitioner claimed to have won chips worth USD 2.1 million, presented chips valued at USD 1.1 million, and was later refused cash redemption by PAGCOR; he deposited chips in a hotel safe each departure.
- Proceedings Below
- Trial Court (RTC Manila, Branch 13) (Decision May 6, 1999)
- Held the Junket Agreement void as PAGCOR lacked authority to lease casino operations (charter violation).
- Found petitioner was on notice of special rules (distinct chips, reserved gaming rooms, posted bilingual disclaimers).
- Dismissed petitioner’s claim for redemption; applied agency, estoppel, and equity principles to leave parties in status quo.
- Court of Appeals (CA) (Decision May 27, 2003; Resolution May 7, 2004)
- Affirmed RTC:
- Petitioner was a junket player subject to special rules; notices properly posted.
- Void contract cannot give rise to implied agency or estoppel.
- No equitable relief to one on clear notice of restrictions.
- Petitioner filed Rule 45 Petition for Review before the Supreme Court.
Issues:
- Whether PAGCOR is liable to petitioner under implied agency or agency by estoppel.
- Whether intent of contracting parties is relevant to create agency affecting a third‐party.
- Whether PAGCOR ratified or adopted the acts of ABS Corporation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)