Title
Philippine Charity Sweepstakes Office vs. Antonio F. Mendoza
Case
G.R. No. 257849
Decision Date
Mar 13, 2023
PCSO refused to pay lottery jackpot to Mendoza due to damaged ticket. Courts ruled in favor of Mendoza, allowing secondary evidence and awarding prize. SC affirmed, emphasizing contract ambiguity and proof burden.

Case Summary (G.R. No. 257849)

Antecedents

On October 2, 2014, Mendoza placed three "lucky pick" bets for the Lotto 6/42 at a lotto outlet in Brgy. Dacanlao, Calaca, Batangas. After learning that one of his combinations was a winning ticket, a series of unfortunate events led to the ticket being partially damaged. Despite attempts to restore the ticket, only fragments remained visible. Mendoza presented this damaged ticket to the PCSO shortly after, leading to a protracted negotiation and legal dispute over the validity of his claim.

Initial Legal Proceedings

Mendoza filed a Complaint for specific performance on September 30, 2015, asserting his claim despite the damaged ticket. He argued that no other claims were submitted for the winnings and contended that the PCSO's "no ticket, no payment" policy lacked a solid legal basis. Mendoza sought the jackpot amount, alongside moral and exemplary damages, attorney's fees, and costs.

PCSO’s Defense and Counterclaims

The PCSO denied Mendoza’s claim, arguing that the absence of the original ticket invalidated his case. They cited rules stating that winning tickets must be presented in their complete and undamaged state. Furthermore, the PCSO emphasized its adherence to internal regulations for preventing fraudulent claims, which they believed Mendoza's case potentially undermined.

Trial Court Decision

The Regional Trial Court (RTC) sided with Mendoza on March 29, 2019, ruling that the evidence presented sufficiently established his entitlement to the jackpot prize despite the condition of the ticket. The RTC ruled that the damage to Mendoza's ticket justified reliance on secondary evidence, allowing him to substantiate his claims and awarded him not only the jackpot but also moral damages and attorney’s fees.

Court of Appeals Ruling

The PCSO appealed the RTC's decision, yet the Court of Appeals (CA) affirmed it but modified the aspects regarding the moral and exemplary damages and attorney's fees. The CA recognized that Mendoza had proven, by preponderance of evidence, that he was the only one to claim the winning combination.

Issues for Resolution

The primary issues presented were whether the provisions in the PCSO Rules were interpretative and whether Mendoza significantly demonstrated ownership of the winning ticket despite its condition.

Supreme Court Ruling

The Supreme Court upheld the CA ruling affirming Mendoza's entitlement to the jackpot prize. It stressed that the ambiguity in the PCSO Rules allowed for judicial interpretation. The Court reiterated that the pertinent criteria for winning consisted in selecting the correct combination of numbers, distinct from the stipulations regarding the ticket’s physical condition.

Interpretation of the PCSO Rules

The Court noted that the PCSO Rules were ambivalent, accommodating both the presentation of a winning ticket and the selection of winning numbers as conditions for entitlement to t

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