G.R. No. 167866 - Pepsi-Cola Products Philippines, Inc. vs. Pagdanga

Case Summary (G.R. No. 167866)

Factual Background

The promotional campaign, which was approved and supervised by the Department of Trade and Industry (DTI), involved the issuance of crowns with winning numbers and corresponding security codes. The initiative aimed to create excitement around their products, with significant cash prizes ranging from P1,000.00 to P1,000,000.00. Following the announcement of the winning number "349," issues arose when multiple customers attempted to redeem crowns with incorrect corresponding security codes. The petitioners communicated that only those crowns bearing the accurate security codes would be honored, while others would be redeemed at a lesser value as an act of goodwill.

Initial Court Ruling

Respondents Pagdanganan and Lumahan, possessing crowns with the number "349" but incorrect security codes, subsequently demanded that the petitioners honor the cash prizes as stated on their crowns. Their demands were met with refusal, resulting in a civil complaint for Sum of Money and Damages filed before the Regional Trial Court (RTC) of Pasig City. The RTC ruled against the respondents, stating they had failed to provide sufficient evidence that would establish a cause of action, thereby dismissing their complaint but awarding minimal goodwill amounts to each respondent.

Court of Appeals Decision

Dissatisfied with the RTC's ruling, the respondents appealed to the Court of Appeals, which reversed the decision of the RTC. The appellate court did not only find in favor of the respondents but awarded them substantially larger sums, arguing that the requirement for a corresponding security code was not explicitly stated in the promotional rules approved by the DTI.

Petitioners’ Argument

The petitioners contended that the Court of Appeals had disregarded established precedents set by prior related cases (Rodrigo, Mendoza, Patan, and De Mesa), arguing that these rulings had clearly defined the requirements for validating winning crowns and upheld the necessity of matching security codes.

Respondents’ Counterarguments

The respondents countered the petitioners' argument by asserting that the specific circumstances of their case differed from the aforementioned cases, emphasizing that their claims were based on breach of contract, not specific performance. They also argued that the finality of the prior judgments did not preclude their right to seek relief, as the facts and laws varied.

Supreme Court Ruling

The Supreme Court analyzed the appeal on several fronts, affirming that the predominant legal principles articulated in earlier rulings indeed applied to the situation at hand, notably the necessity of having both the winning number and corresponding security code. It underscored the application of the doctrine of stare decisis, which mandates adherence to established judicial precedence to prot