GR 146007; (June, 2006) (Digest)
G.R. No. 146007 & G.R. No. 146295; June 15, 2006
PEPSICO, INC. and PEPSI-COLA PRODUCTS PHILS., INC., Petitioners, vs. JAIME LACANILAO and COURT OF APPEALS, Respondents.
FACTS
Petitioners Pepsi-Cola Products Phils., Inc. (PCPPI) and PEPSICO, Inc. conducted a “Number Fever” promotional campaign. The winning numbers were pre-selected by a Mexican consulting firm, with the process approved by the DTI. A list of winning numbers with corresponding security codes was deposited in a bank safety deposit box. During an extended promotional period, petitioners erroneously announced “349” as a winning number. Verification with the secured list revealed that crowns bearing “349” with security codes “L-2560-FQ” and “L-3560-FQ” were not winning entries. Petitioners consequently refused to honor such crowns, including those held by respondent Jaime Lacanilao.
Respondent filed a complaint for recovery of the cash prize. The trial court ruled in his favor, a decision affirmed with modification by the Court of Appeals, which ordered petitioners to pay him P1,050,000 as the aggregate prize for his two crowns but deleted the award of damages. Petitioners elevated the case to the Supreme Court via consolidated petitions for review.
ISSUE
Whether respondent is entitled to the cash prize for his bottle caps bearing the number “349.”
RULING
No. The Supreme Court reversed the Court of Appeals. The legal logic is anchored on the principle of stare decisis and the finality of rulings in parallel cases. The Court emphasized that the facts, causes of action, and issues in this case are identical to those in the previously decided cases of Rodrigo v. PCPPI and Mendoza v. PCPPI, which attained finality. In those cases, the Court definitively ruled that the security code was an indispensable element of a winning crown and that petitioners were not negligent in conducting the promotion.
Since respondent’s crowns bore the non-winning security codes, he did not hold a valid winning entry. To rule otherwise would create conflicting decisions on the same set of facts, undermining judicial stability and equality. The Court also noted that respondent had withdrawn all claims against petitioners. Therefore, petitioners incurred no liability for the payment of the prize or for damages. The reversal of the appellate court’s judgment was necessary to maintain consistency with established jurisprudence.