Title
Manila Jockey Club, Inc. vs. Games and Amusements Board
Case
G.R. No. L-12727
Decision Date
Feb 29, 1960
Manila Jockey Club challenged GAB's allocation of Sundays for PCSO's sweepstakes races, claiming vested rights. SC upheld GAB's discretion, ruling no vested rights to unreserved days and no deprivation of property under voluntary lease agreements.
private racing clubs
unreserved racing days
additional sweepstakes races

Case Summary (G.R. No. L-12727)

Factual Background

The controversy arose when Republic Act No. 1502 increased the authorized sweepstakes draws and races of the Philippine Charity Sweepstakes Office from six to twelve without specifying the days on which the additional races were to be held. Under the existing statutory allocation in Republic Act No. 309, certain Sundays and Saturdays had been expressly reserved for specified charitable institutions and for races authorized by the President, while private licensees were permitted to hold races on unreserved Sundays, on twenty-four Saturdays as determined by the Commission on Races (now Games and Amusements Board), and on most legal holidays. To accommodate the six additional sweepstakes races, the Games and Amusements Board adopted a resolution reducing by six the number of Sundays available to private licensed clubs and assigning those Sundays to the Philippine Charity Sweepstakes Office.

Statutory Framework

Section 4 of Republic Act No. 309, as amended by Republic Act No. 983, expressly allocated racing days among charitable institutions, the President, and private licensees. The statute reserved twenty-three Sundays and sixteen Saturdays for the Philippine Anti-Tuberculosis Society, the Philippine Charity Sweepstakes Office, and the White Cross, Inc.; it reserved twelve Saturdays to the President for charitable, relief, or civic purposes; it permitted private individuals and entities duly licensed by the Commission on Races to hold races on Sundays not reserved under the Act, on twenty-four Saturdays as determined by the Commission, and on legal holidays except specified days. Republic Act No. 1502 authorized six additional regular sweepstakes draws and races but did not designate the days for those additional events.

Procedural History

The Manila Jockey Club, Inc. filed a petition for declaratory relief in the Court of First Instance of Manila challenging the placement of the additional sweepstakes races and the authority of the Philippine Charity Sweepstakes Office to use the petitioner's race track and equipment. Philippine Racing Club, Inc. intervened with leave of court. The trial court rendered judgment on July 5, 1957, holding that the Philippine Charity Sweepstakes Office was authorized to hold one regular sweepstakes draw and races once a month on a Sunday not reserved for the named charitable institutions and that the use of petitioners' premises occurred under lease agreements so as not to constitute a deprivation without due process. The petitioners appealed.

Issues Presented

The principal issues were whether the six additional sweepstakes races authorized by Republic Act No. 1502 should be scheduled from the twelve Saturdays reserved to the President, from other days of the week outside Sundays, Saturdays, and legal holidays, or from the Sundays on which private licensed clubs had been permitted to race; and whether the Philippine Charity Sweepstakes Office could appropriate or use the petitioners' race tracks and equipment without their consent or under threat of license revocation.

Trial Court Ruling

The Court of First Instance found that there was no deprivation of property without due process because the Philippine Charity Sweepstakes Office was using the petitioners' premises and equipment under separate contracts of lease for payment of rentals. The trial court further held that, in light of Republic Act No. 1502, the Philippine Charity Sweepstakes Office was authorized to hold one regular sweepstakes draw and races once a month on a Sunday not reserved for specified charitable institutions, thereby reducing the Sundays available to private entities.

Parties' Contentions on Appeal

The appellants contended that the six additional sweepstakes races ought to be taken from the twelve Saturdays reserved to the President or be assigned to any other day of the week besides Sunday, Saturday, and legal holiday. They further argued that, if the additional sweepstakes races fell on days already allotted to club races, the sweepstakes should be inserted into the club race program rather than the whole day being given exclusively to the Philippine Charity Sweepstakes Office. The appellees defended the Games and Amusements Board resolution as a lawful exercise of the statutory discretion granted by Republic Act No. 309 and maintained that the Philippine Charity Sweepstakes Office had not deprived petitioners of property because its use of facilities was by lease.

Legislative History and Debate

Appellants relied upon floor statements during the House debate on House Bill No. 5732, which became Republic Act No. 1502, where Representatives Marcos and Abeleda stated an intention that additional sweepstakes races should be inserted in club race days when they fell on such days. The Court noted these remarks in the record but reviewed authorities on the admissibility and weight of legislative debates. It observed that speeches of individual legislators are not a reliable guide to the collective intent of the legislature and that, in this instance, nothing in the final enacted text of Republic Act No. 1502 evidenced that the informal understanding of those two members had received the sanction of Congress.

Legal Reasoning of the Court

The Court emphasized that the specific Sundays and Saturdays expressly reserved by statute for the named charitable institutions and for races authorized by the President could not be reallocated by the Games and Amusements Board without statutory authority. The Court then focused on the residual racing days permitted by Section 4 of Republic Act No. 309—Sundays not reserved by the Act, twenty-four Saturdays as the Commission might determine, and legal holidays—and concluded that private clubs possessed only permissive, not vested, rights to those days because their authority to race there was subject to licensing and the determination of the Games and Amusements Board. Given that Republic Act No. 1502 increased the number of sweepstakes races without designating days, the Games and Amusements Board lawfully made room for the additional races by reallocating available unreserved days. The Court rejected the suggestion that weekday races were permissible because Article 198 of the Revised Penal Code prohibited holding races with betting on week days. The Court also regarded the long-standing practice and contemporaneous exposition—namely, that sweepstakes draws and races were held on Sundays and occupied a whole day—as significant in ascertaining the intended operation of the statute. The Court found that regular sweepstakes races were ordinarily held on whole days and that the statutory authorization of additional regular sweepstakes races supported the conclusion that Congress intended whole-day sweepstakes sep

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