Mirando v. Philippine Charity and Sweepstakes Office
REITERATIONFacts
The Antecedents: Petitioner Carlito L. Mirando, Jr. claimed to be the owner of a winning lottery ticket for the March 9, 1996 draw of the Philippine Charity Sweepstakes Office (PCSO), with winning numbers 15-22-23-24-34-36, for a jackpot prize of ₱120,163,123.00. He alleged purchasing the ticket at the ACT Theater lotto outlet in Cubao, Quezon City, and later presenting it to PCSO Chairman Manolito Morato on March 18, 1996, who informed him that the prize had already been claimed by someone else and that his ticket was altered. Procedural History: Petitioner filed a complaint for damages against PCSO and Morato before the Quezon City Regional Trial Court (RTC), seeking the jackpot prize, moral and exemplary damages, and attorney's fees. The RTC dismissed the complaint, finding that the preponderance of evidence favored the respondents. The RTC held that respondents sufficiently established that the winning ticket was sold at the Zenco Footsteps lotto outlet in Pasay City and had already been claimed, and that the purported winning message on the monitor screen was not possible with the lotto machines used. The RTC also found petitioner's ticket to be tampered with and concluded that petitioner himself tampered with it after the draw. The Court of Appeals (CA) affirmed the RTC ruling in toto, adding further observations that supported the trial court's findings, including the type of lotto machine used and the lack of corroboration for petitioner's claims. The Petition: Petitioner filed a petition for review on certiorari before the Supreme Court, assailing the CA's decision. He argued that the CA erred in not giving full weight to his testimonial and documentary evidence, which he claimed outweighed the respondents' evidence, and in failing to consider applicable laws and jurisprudence.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court's finding that the preponderance of evidence lies with the respondents. Whether the issue of who was the rightful winner of the lotto jackpot prize presents a question of fact or a question of law.
Ruling
The petition is denied. The January 31, 2012 Decision and November 15, 2012 Resolution of the Court of Appeals in CA-G.R. CV No. 86399 are affirmed.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the Regional Trial Court's finding that the preponderance of evidence lies with the respondents: The Court held that a determination of where the preponderance of evidence lies is a factual issue. This requires an appreciation of the relative weight of the competing parties' evidence, which is not the office of a Rule 45 petition. The findings of the trial court, especially when affirmed by the Court of Appeals, are conclusive on the Supreme Court when supported by the evidence on record. In this case, both the RTC and the CA independently scrutinized the record and substantiated their respective decisions with relevant evidence showing that petitioner's complaint was bereft of factual and legal bases. The Court noted that at the end of the day, petitioner was in possession of a tampered lotto ticket, and neither the alleged meeting with Morato nor the alleged tampering by Morato was proven by petitioner. The burden of proof rests on the party alleging a fact, and a mere allegation is not evidence. On the issue of whether the question of who was the rightful winner of the lotto jackpot prize presents a question of fact or a question of law: The Court reiterated that a Rule 45 petition pertains to questions of law and not to factual issues. A question of law arises when there is doubt as to what the law is on a certain state of facts, while a question of fact arises when the doubt pertains to the truth or falsity of the alleged facts or requires a calibration of evidence. To resolve the issue of whether petitioner was the jackpot prize winner, the Court would need to examine the records, evaluate the documentary and testimonial evidence, and decide on which side the preponderance of evidence lies. This process inherently involves a determination of facts, making it unsuitable for a Rule 45 petition. Therefore, the Court found no reversible error in the CA's affirmation of the RTC's decision.
Main Doctrine
A petition for review on certiorari under Rule 45 of the Rules of Court pertains to questions of law, not factual issues. A determination of whether the preponderance of evidence lies with a party is a question of fact, which requires an appreciation of the relative weight of competing evidence, and thus cannot generally be entertained in a Rule 45 petition. The findings of the trial court, especially when affirmed by the Court of Appeals, are conclusive on the Supreme Court when supported by the evidence on record.