Title
Jaworski vs. Philippine Amusement and Gaming Corp.
Case
G.R. No. 144463
Decision Date
Jan 14, 2004
PAGCOR's grant of authority to SAGE for internet gambling was nullified as it exceeded P.D. No. 1869's scope, violated territorial limits, and lacked legislative approval.

Case Summary (G.R. No. 144463)

Petitioner

Senator Robert S. Jaworski, in his capacity as Chairman of the Senate Committee on Games, Amusements and Sports, challenged PAGCOR’s grant to SAGE of authority to conduct online gambling.

Respondents

  1. Philippine Amusement and Gaming Corporation (PAGCOR), a government-owned and controlled corporation created by Presidential Decree No. 1869.
  2. Sports and Games Entertainment Corporation (SAGE), a private entity granted the authority to operate sports betting and internet gaming.

Key Dates

• July 11, 1983 – Issuance of P.D. 1869 establishing PAGCOR’s franchise.
• March 31, 1998 – PAGCOR Board approves the “Grant of Authority and Agreement” with SAGE.
• September 1, 1998 – PAGCOR and SAGE execute the agreement.
• October 10, 2005 – En banc decision rendered by the Supreme Court under the 1987 Constitution.

Applicable Law

• Presidential Decree No. 1869 (PAGCOR’s legislative franchise).
• 1987 Philippine Constitution (governing Act).
• Rule 65, Sections 1–2, Rules of Court (certiorari and prohibition).

Procedural Posture and Remedies

Petitioner filed a petition for certiorari and prohibition directly with the Supreme Court under Rule 65, seeking nullification of PAGCOR’s grant of authority to SAGE. Respondents moved to dismiss for lack of standing and improper invocation of extraordinary remedies.

Legal Standing of Petitioner

The Court held that although members of Congress ordinarily must show personal and legislative impact, the issues’ public significance justified waiving strict standing requirements. Petitioner was deemed to have sufficient interest to challenge the grant on behalf of public welfare.

Jurisdiction Under Rule 65

Respondents argued PAGCOR’s licensing function is neither judicial nor quasi-judicial, thus outside Rule 65. The Court reiterated its discretion to entertain matters of transcendental importance and characterized the petition as one for prohibition to prevent enforcement of the contested agreement.

Scope of PAGCOR’s Franchise

Under P.D. 1869, PAGCOR’s franchise authorizes it to operate casinos, clubs, sports pools, and other forms of gambling “on land or water within the territorial jurisdiction of the Republic.” Internet gambling was not contemplated in 1983 and transcends national boundaries, thus falling outside the enumerated activities.

Reservation of Franchise and Non-Delegability

A legislative franchise is a special privilege that may not be arbitrarily assigned or shared. The principle delegata potestas non delegari prohibits PAGCOR from transferring or sharing its franchise. While PAGCOR may enter management contracts, it cannot vest franchise rights in another entity absent express legislative authorization.

Precedents on Joint Venture

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