G.R. No. 207118 , April 22, 2025
Case Parties: [Petitioner vs. Respondent – Not fully named in provided text]

FACTS

The case concerns the legality of “Bingo sa Barangay” as a local fund-raising activity. The ponencia (majority opinion) held that this activity falls outside the scope of the Anti-Illegal Gambling Law, as it is a legitimate fund-raising endeavor authorized under Section 391 of the Local Government Code (LGC). The ponencia further relied on an amendment in Republic Act No. 9487 , which provides that the Philippine Amusement and Gaming Corporation’s (PAGCOR) authority does not extend to games of chance authorized and regulated by local government units (LGUs).
Justice Singh, in a dissenting opinion, contests this conclusion. The dissent argues that the ponencia’s position incorrectly assumes that LGU approval alone suffices, without requiring compliance with national policy standards. The dissent emphasizes that Section 391 of the LGC mandates that local fund-raising activities must still adhere to national policies on morals, health, and safety.

ISSUE

Whether “Bingo sa Barangay,” as a game of chance conducted by a barangay, is a lawful fund-raising activity exempt from PAGCOR’s licensing authority and the prohibitions of the Anti-Illegal Gambling Law.

RULING

Justice Singh dissents, voting to grant the petition and declare “Bingo sa Barangay” illegal. The legal logic is anchored on a harmonized interpretation of the LGC and PAGCOR’s charter. First, the dissent clarifies that the exception under RA 9487, which excludes from PAGCOR’s authority “games of chance… authorized, licensed and regulated by local government units,” refers only to activities where the LGC explicitly grants such power. The LGC does not grant blanket authority to LGUs to authorize all games of chance for fund-raising.
Second, a review of the LGC reveals a clear legislative intent to distinguish between prohibited and permissible games. Provisions under Sections 447, 458, and 468 direct local sanggunians to enact ordinances to “prevent, suppress and impose appropriate penalties for gambling and other prohibited games of chance.” Conversely, the LGC explicitly authorizes LGUs to license and regulate only cockfighting and cockpits. “Bingo” is not among the expressly permitted activities.
Third, the dissent invokes the doctrine in Magtajas v. Pryce Properties, which mandates harmonizing statutes. The proper interpretation is that LGUs must prevent all forms of gambling except those specifically allowed by statute like P.D. No. 1869 (the PAGCOR Charter). Since the LGC does not expressly authorize barangay bingo, it remains prohibited. Finally, policy considerations weigh against its allowance, as it exposes low-income communities to the pernicious effects of gambling under the guise of a harmless community activity.