Case Summary (G.R. No. L-12727)
Petitioner
Manila Jockey Club, Inc., joined by the Philippine Racing Club as intervenor, sought declaratory relief contesting (a) the placement of the six additional PCSO races and (b) the alleged power of PCSO or respondents to appropriate or use petitioners’ race tracks and equipment without consent or under threat of license revocation.
Respondent
Games and Amusements Board (GAB) implemented an allocation reducing the number of Sundays available to private racing clubs to accommodate the six additional PCSO races; the PCSO conducted sweepstakes races and drew on race tracks, and Executive Secretary Fortunato de Leon was joined as a party.
Key Dates
Lower court judgment rendered July 5, 1957; appeal to the Supreme Court resulted in the decision reproduced in the prompt. (Decision date used for constitutional context is in the case record.)
Applicable Law (including constitutional context)
Primary statutes: Republic Act No. 309 (as amended by R.A. 983) establishing and allocating racing days; Republic Act No. 1502 (authorizing an increase of PCSO sweepstakes draws and races from six to twelve) and the general penal prohibition against weekday betting referenced via Article 198 of the Revised Penal Code. The Constitution in force at the time of decision was the 1935 Philippine Constitution, which provides the broader legal backdrop.
Procedural History
Petitioner filed for declaratory relief in the Court of First Instance of Manila (Civil Case No. 31274); the Philippine Racing Club intervened. The trial court found no deprivation of property without due process because use of premises by PCSO occurred under separate voluntary lease contracts, and held that R.A. 1502 authorized the PCSO to hold one sweepstakes draw and races once a month on a Sunday not reserved for specified charitable institutions, thereby reducing Sundays available to private entities. Petitioners appealed.
Issue Presented
Whether the six additional PCSO sweepstakes draws and races authorized by R.A. 1502 must be scheduled on (a) Saturdays reserved to the President for charitable purposes, (b) other non-weekend days, or (c) taken from the unreserved Sundays previously permitted to private clubs under R.A. 309; and whether compelling petitioners to allow PCSO use of their premises without consent constitutes deprivation of property without due process.
Statutory Scheme of Racing Days under R.A. 309 (as amended)
Section 4 of R.A. 309 (amended by R.A. 983) expressly reserved certain Sundays and Saturdays for named charitable institutions (totaling 23 Sundays reserved for Anti‑Tuberculosis Society, PCSO, White Cross, and a Grand Derby) and specified 12 Saturdays for the President’s authorization for other charitable, relief, or civic purposes. The statute left other Sundays unreserved and permitted private licensed entities to hold races on those Sundays, on twenty‑four Saturdays as determined by the GAB, and on legal holidays (with enumerated exceptions).
Effect of R.A. 1502 and GAB Resolution
R.A. 1502 increased PCSO sweepstakes draws and races to twelve without specifying the days. The GAB responded by reallocating available racing days and reduced the number of Sundays allotted to private clubs by six to accommodate the PCSO increase. Petitioners argued instead that the increase should come from the 12 Saturdays reserved for Presidential authorization or from other weekdays.
Court’s Analysis on Vested Rights and GAB Discretion
The Court found that private clubs had no vested right to the "unreserved" Sundays or to the 24 Saturdays the GAB determines; those allowances were permissive and subject to licensing and the GAB’s determination under R.A. 309. Because R.A. 309 and R.A. 983 had expressly reserved certain days that could not be altered absent law, the only available days to satisfy R.A. 1502 were the unreserved days permissibly allocated by the GAB. The Court concluded the GAB acted within the discretion conferred by statute in reallocating unreserved Sundays to PCSO.
Legislative Debate and Use of Extrinsic Aids
Petitioners pointed to floor statements indicating an intent to insert additional PCSO races into club race days. The Court acknowledged conflicting authorities on the admissibility and weight of legislative debates but emphasized that the enacted statute contained no express provision adopting that floor understanding. The Court held that individual legislative remarks cannot override the statutory language and that it would be improper to supply terms not expressed in the statute.
Contemporaneous Practice and Meaning of "Regular" Sweepstakes
The Court considered contemporaneous practice: historically, sweepstakes draws and races were held on Sundays for the whole day. Given Congr
...continue readingCase Syllabus (G.R. No. L-12727)
Procedural History
- Petition for declaratory relief was filed by Manila Jockey Club, Inc. in the Court of First Instance of Manila (Civil Case No. 31274).
- Philippine Racing Club, Inc. intervened as party in interest with leave of court.
- Respondents were Games and Amusements Board (GAB), Philippine Charity Sweepstakes Office (PCSO), and Executive Secretary Fortunato de Leon; respondents filed answers.
- The trial court rendered a decision on July 5, 1957, prominently holding that PCSO was authorized to hold one regular sweepstakes draw and races once a month on a Sunday not reserved for specified charities, pursuant to Section 9 of Republic Act No. 1502, thereby reducing Sundays allotted to private entities.
- Petitioners (Manila Jockey Club and intervenor Philippine Racing Club) appealed the trial court’s judgment to the Supreme Court; the appeal is reported here.
- The Supreme Court, through Justice Barrera, reviewed the statutory provisions, legislative history, and prevailing practice, and affirmed the lower court’s decision, with costs against appellants.
Parties and Positions
- Appellants/Petitioners:
- Manila Jockey Club, Inc. (petitioner and appellant).
- Philippine Racing Club, Inc. (petitioner-intervenor and appellant).
- Sought a declaratory interpretation that: (a) the 30 Sundays unreserved for charitable institutions continue to belong to private racing clubs under Section 4 of RA 309; (b) the six additional sweepstakes races authorized by RA 1502 should be held on 6 of the 12 Saturdays reserved to the President or on other weekdays besides Sunday, Saturday, and legal holiday; (c) PCSO cannot appropriate or use petitioners’ race tracks and equipment without consent or under threat of license revocation.
- Respondents/Appellees:
- Games and Amusements Board (GAB): implemented a resolution reducing private clubs’ Sundays by six to accommodate RA 1502’s additional PCSO races.
- Philippine Charity Sweepstakes Office (PCSO): claimed authority under RA 1502 to increase its sweepstakes draws and races to twelve and used private club facilities pursuant to lease contracts.
- Executive Secretary Fortunato de Leon: named respondent.
Statutory Framework and Relevant Provisions
- Republic Act No. 309 (basic law on horse racing), as amended by Republic Act No. 983, particularly Section 4, distributes authorized racing days among charities, PCSO, private licensees, and the President’s discretionary Saturdays.
- The statutory allocation of racing days as presented in the source material:
- Sundays:
- Philippine Anti-Tuberculosis Society: 12 Sundays
- Philippine Charity Sweepstakes Office (PCSO): 6 Sundays
- White Cross, Inc.: 4 Sundays
- Grand Derby Race of the Philippine Anti-Tuberculosis Society: 1 Sunday
- Total explicitly reserved: 23 Sundays
- For private individuals/entities licensed by GAB: other Sundays not reserved — 29 Sundays or 30 in leap years (total for year 52 Sundays; 53 in leap years)
- Saturdays:
- Philippine Anti-Tuberculosis Society: 12 Saturdays
- White Cross, Inc.: 4 Saturdays
- Private individuals/entities licensed by GAB and as determined by it: 24 Saturdays
- Races authorized by the President for charitable/relief/civic purposes (other than the charities named): 12 Saturdays
- Total Saturdays: 52
- Legal holidays:
- All legal holidays except Thursday and Friday of Holy Week, July 4 (Independence Day), and December 30 (Rizal Day) are reserved for private licensees.
- Sundays:
- Republic Act No. 1502 (approved June 16, 1956) increased the sweepstakes draws and races of PCSO from six to twelve but did not specify the days on which the additional races were to be run.
- Section 9 of RA 1502 was cited by the trial court as authorizing the PCSO to hold the additional sweepstakes.
- Article 198 of the Revised Penal Code is referenced as prohibiting the holding of horse races with betting on weekdays.
Facts Pertinent to the Dispute
- RA 1502 increased PCSO’s authorized sweepstakes draws and races to twelve without designating specific days.
- GAB, to accommodate the additional sweepstakes races, resolved to reduce the number of Sundays assigned to private individuals and entities by six.
- Appellants protested, arguing that:
- The six additional sweepstakes races should be taken from the 12 Saturdays reserved to the President for charitable, relief, or civic purposes; or
- The additional races should be scheduled on days other than Sunday, Saturday, or legal holiday.
- PCSO, when using appellants’ premises and equipment, did so under separate contracts of lease and paid corresponding rentals.
- Historical practice: sweepstakes draws and races had long been held on Sundays and occupied the whole day.
Issues Presented
- Primary legal issue: What is the proper placement (days) for the six additional racing days given to the PCSO by RA 1502?
- Subsidiary issues:
- Whether GAB had authority to reallocate racing days reserved to private licensees to accommodate the PCSO’s increase in races under RA 1502.
- Whether the six additional sweepstakes races should have been taken from the Saturdays reserved for the President or assigned to other weekdays or Saturdays, rather than reducing private clubs’ Sundays.
- Whether legislative floor debates (statements by individual congressmen) could be used to interpret RA 1502 to require that sweepstakes races be inserted into club race days.
- Whether compelling appellants to permit PCSO’s use of their facilities without consent would constitute deprivation of property without due process of law.
Trial Court’s Findings and Holding (as summarized in the source)
- The trial court declined to rule on deprivation of property without due process because the PCSO used petitioners’ premises under voluntary, separate lease contracts with rental payments; therefore, no deprivation with