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.
A

Case Summary (G.R. No. 257849)

Factual Background

Mendoza alleged that on October 2, 2014 he placed three bets by “lucky pick” at a lotto outlet in Brgy. Dacanlao, Calaca, Batangas. He later learned that one of his three bet combinations matched the official winning six-number combination for Draw 1055. His physical ticket, however, was partly blackened when a family member attempted to straighten and iron it; only the first two digits of each of the three bet rows and certain transactional details remained visible. Mendoza presented the damaged ticket to the sweepstakes office in early October 2014, provided written accounts and affidavits, underwent polygraph tests, and pursued his claim before the House Committee on Games which issued Committee Report No. 717 recommending award to him. PCSO nevertheless refused payment, invoking a “no ticket, no payment” policy and the PCSO Rules provision that prizes would not be paid if the ticket were altered, defaced, torn, damaged or failed validation tests.

Trial Court Proceedings

Mendoza filed a complaint for specific performance on September 30, 2015, praying for payment of PHP 12,391,600.00 plus moral and exemplary damages, attorney’s fees, and costs. PCSO answered and pleaded that the complaint failed to state a cause of action for lack of the original winning ticket and relied on ticket terms and the PCSO Rules, including Article VII(4)(c) that “PCSO shall not consider payment of any prize without the presentation and surrender of the winning ticket.” The RTC conducted preliminary hearings on PCSO’s special affirmative defenses and ultimately resolved factual disputes, found Mendoza to have established by preponderance of evidence that he selected the winning number combination, resorted to secondary evidence because the original ticket was damaged, and rendered judgment on March 29, 2019 directing PCSO to pay the jackpot and awarding moral, exemplary damages and attorney’s fees.

Court of Appeals Ruling

PCSO appealed. The Court of Appeals affirmed the RTC’s factual finding that Mendoza had selected the winning six-number combination and was therefore entitled to the jackpot. The CA reasoned from the PCSO Rules’ definitions that the essence of winning the Lotto 6/42 prize is selecting the winning number combination and that a ticket functions as proof of that selection. The CA nevertheless found insufficient basis for awards of moral and exemplary damages and attorney’s fees and deleted those awards while affirming the payment of PHP 12,391,600.00.

Parties’ Contentions Before the Supreme Court

PCSO petitioned for review under Rule 45, Rules of Court, seeking reversal on the ground that the CA disregarded clear PCSO Rules that make presentation of a valid ticket a condition precedent to payment. PCSO urged that allowing secondary or testimonial evidence in lieu of a pristine original would invite fraud and undermine lottery integrity, and it invoked precedents arising from the “Number Fever” cases to argue that failure to comply with conditions precedent defeats entitlement to prize. Mendoza maintained that the PCSO Rules were ambiguous and that he had proved by preponderance of evidence that he had selected the winning number combination.

Issues Presented

The Supreme Court framed the issues as: (i) whether the provisions in the PCSO Rules for the Lotto 6/42 are susceptible to judicial interpretation; and (ii) whether Mendoza proved entitlement to the jackpot despite a partially burned ticket.

Ruling of the Supreme Court

The Supreme Court denied the petition. It affirmed the Court of Appeals’ decision and resolution with modifications and ordered PHILIPPINE CHARITY SWEEPSTAKES OFFICE to pay ANTONIO F. MENDOZA PHP 12,391,600.00 as jackpot, plus legal interest at six percent per annum from finality of the decision until full payment.

Legal Basis and Reasoning

The Court first held that the PCSO Rules were ambiguous because they permitted at least two reasonable interpretations: PCSO’s interpretation that physical presentation of an intact ticket is a condition precedent to payment, and Mendoza’s interpretation that the essential element of winning is selection of the winning number combination. The Court explained that where a written rule is susceptible of two reasonable meanings the interpretation becomes a judicial function and cannot be resolved solely as a question of law. The Supreme Court then emphasized that the lottery game is a number-match game under the PCSO Rules and that the definitions in Article II refer to a winning number combination and to a ticket merely as evidence produced by a terminal confirming the selection. The Court therefore concluded that the act of selecting the winning combination is the dispositive act that entitles a bettor to a prize.

Findings on Evidence and the Best Evidence Rule

The Court reiterated that it is not a trier of facts and that determinations of preponderance of evidence are factual questions requiring appreciation of competing evidence. The Court adopted the RTC’s and CA’s factual findings that Mendoza proved by preponderance that he placed the winning selection and that no other claimant sought the jackpot. On the evidentiary issue, the Court clarified the scope of the Best Evidence Rule under Rule 130, Rules of Court and the admissibility of secondary evidence. It explained that when the dispute concerns the existence or execution of a document rather than its content, the best evidence rule does not preclude testimonial or secondary evidence. Because PCSO contested the ticket’s existence and presentation rather than contesting the numerical content as a matter of record, the testimonial and documentary evidence Mendoza offered and PCSO’s own records were admissible and duly weighed.

Distinction from the “Number Fever” Cases

The Court distinguished the present case from the Pepsi-Cola Products Philippines, Inc. v. Pagdanganan line of

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