Case Summary (G.R. No. 152927)
Case Background
The case originates from a promotional campaign launched in 1991 by Pepsi Cola Products (Philippines), Inc. called the "Number Fever," aimed at incentivizing consumers to participate by searching for specific winning crowns on its soft drink products. This campaign, approved and monitored by the Department of Trade and Industry (DTI), involved numbers affixed to crowns, with the winning combinations carefully selected and stored in a safety deposit box. On May 25, 1992, the company announced a number combination, which led to a surge of claims from individuals holding non-winning caps. In a bid to quell unrest stemming from these claims, Pepsi offered ₱500 for non-winning crowns, which 490,116 participants accepted.
Legal Proceedings
Respondents Patan, Jr., Apanto, Jr., Pongcol, and Pestano rejected the goodwill offer and instead filed complaints against Pepsi seeking specific performance and recovery of alleged prizes. The cases were consolidated and, following a trial, the Regional Trial Court dismissed the complaints due to lack of cause of action. The respondents appealed this decision, but two failed to pay docket fees, leading to the abandonment of their appeals. Ultimately, the Court of Appeals affirmed the trial court's findings, concluding that the respondents did not win; however, it awarded ₱500 to each of them based on equity.
Petitioner’s Allegations
Pepsi contested the appellate court's decision, arguing that it deviated from established jurisprudence by granting ₱500 to the respondents despite the finding that they were not at fault or negligent. Furthermore, Pepsi highlighted that the Court of Appeals had granted relief to parties whose appeals were not perfected, which contravened prevailing legal principles regarding res judicata and stare decisis.
Court's Finding on Appeals
The Supreme Court agreed with Pepsi’s position regarding the appeals. It noted that the Court of Appeals had acknowledged the abandonment of appeals by Apanto and Pongcol due to non-payment of fees. Thus, the Court of Appeals erred in awarding relief to respondents who failed to perfect their appeals, which should have precluded them from obtaining any affirmative relief.
Rejection of Equity Argument
The Court also rejected the notion that equity provided a proper basis for awarding ₱500 to respondent Patan, Jr. Unlike the large num
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Case Overview
- The case involves a petition for review on certiorari filed by Pepsi Cola Products (Phils.), Inc. (petitioner) against Rustico P. Patan, Jr., Gregorio C. Apanto, Jr., Genelyn Pongcol, and Dennis Pestano (respondents).
- The primary issue is the Court of Appeals' directive for the petitioner to pay the respondents P500 each based solely on equity, despite the finding that the petitioner was not at fault or negligent.
- The decision under review stemmed from the Court of Appeals' ruling dated October 18, 2001, and its Resolution dated April 10, 2002.
Background Facts
- In 1991, the petitioner launched a promotional campaign called "Number Fever" for its soft drink products, with crowns (caps) bearing winning numbers and security codes.
- The campaign was approved by and supervised by the Department of Trade and Industry (DTI). Winning crowns were stored in a safety deposit box.
- On May 25, 1992, the number "349" was announced as a winning combination for the following day, but it was later confirmed that the reported non-winning crowns were not legitimate.
- To mitigate backlash, the petitioner offered P500 for each non-winning "349" crown until June 12, 1992. Approximately 490,116 claimants accepted this offer.
- The respondents, holding non-winnin