G.R. No. L-45993; May 11, 1939
Geronimo Santiago, Jr. vs. Fabian R. Millar, as Manager of the Philippine Charity Sweepstakes

FACTS

Plaintiff Geronimo Santiago, Jr., an agent of the Philippine Charity Sweepstakes, purchased booklets of tickets for a draw. Ticket No. 0293020, included in his purchase, won a prize. Two units (one-half) of this winning ticket were given to him as a gift by Carmen B. Garcia, who had purchased them from him. These two units were subsequently lost. The ticket contained a printed condition: “prizes of tickets sold locally will be paid to holder of ticket upon surrender of same.” Plaintiff notified the defendant, the Sweepstakes Manager, of the loss and filed a complaint seeking to be declared the owner entitled to the prize and to restrain payment to others. The trial court ruled in favor of the plaintiff.

ISSUE

Whether the plaintiff, having lost the winning sweepstake ticket, can still collect the prize without surrendering the ticket as required by its printed condition.

RULING

No. The judgment of the lower court is reversed. The printed condition on the ticket requiring its surrender for payment is a valid condition precedent. The contract is aleatory, and the parties may establish such terms provided they are not contrary to law, morals, or public order. Obligations arising from contracts have the force of law between the parties and must be performed according to their stipulations. Since the plaintiff failed to comply with the condition of surrendering the ticket, he cannot collect the prize.

DISSENTING OPINION (Villa-Real, J.):
The surrender of the ticket is merely evidentiary, as the ticket is the best evidence of the debt. The loss of the evidence does not extinguish the underlying obligation. The creditor should be allowed to prove the contents of the lost ticket by secondary evidence and collect the prize, consistent with general principles of equity and the rules on evidence for ordinary debts.