Title
Pepsi Cola Products , Inc. vs. Espiritu
Case
G.R. No. 150394
Decision Date
Jun 26, 2007
Pepsi's "Number Fever" campaign in the Philippines led to disputes over unauthorized winning numbers; SC ruled in favor of Pepsi, citing non-matching security codes and precedent.

Case Summary (G.R. No. 150394)

Factual Background

In 1992, Pepsi Cola Products Philippines, Inc. launched the "Number Fever" promotion, inviting consumers to check for winning numbers under the caps of its soft drink products. Approved by the Department of Trade and Industry (DTI), the campaign produced a list of predetermined winning numbers secured in a bank. On May 25, 1992, the number 349 was announced, leading numerous consumers to believe they had won. However, subsequent verification revealed discrepancies with the security codes, leading PCPPI to revoke the winning status of the number 349.

Legal Proceedings Initiated by Respondents

Upon learning that their crowns bearing the number 349 were not recognized as winning, the respondents, along with other holders of these crowns, participated in collective actions against PCPPI. They formed the Ugnayan 349 Association Inc., which sent several demand letters for payment. The respondents subsequently filed a complaint for collection and damages before the Regional Trial Court (RTC) of Quezon City, which became part of a series of lawsuits stemming from the same promotional incident.

RTC Decision

In a judgment issued on June 24, 1996, the RTC ruled that while the claimants were not entitled to their prize amounts, PCPPI was ordered to pay each claimant moral damages of P10,000.00. This initial ruling, although recognizing the plaintiffs' claim for damages, limited the remedy available to them, which was contended by both the respondents and PCPPI in separate appeals.

Court of Appeals Decision

The Court of Appeals (CA) affirmed the RTC's decision regarding the moral damages while increasing the awarded amount to P30,000.00 for each respondent, along with an award for attorney’s fees. The CA found justification for the moral damages, reaffirming the distress caused to the respondents due to the error in the promotion and PCPPI’s subsequent actions.

Supreme Court Analysis

In its review, the Supreme Court emphasized the principle of stare decisis, noting that prior rulings in similar cases, specifically those of Mendoza and Rodrigo, established that winning crowns must have matching security codes to be valid. These cases had concluded that holders of the crowns with incorrect codes were not entitled to the advertised prizes, thus solidifying PCPPI’s non-liability for the amounts represented on those crowns.

Final Ruling

The

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