Rubis v. Philippine Charity Sweepstakes
REITERATIONFacts
The Antecedents: On March 4, 1938, Tranquilino Rubis filed an action against the Philippine Charity Sweepstakes for the recovery of P1,000, representing the prize for unit of ticket No. 281945, which allegedly won the fifth prize in a draw held on September 8, 1937. The plaintiff claimed to be the owner of the ticket, which he bought from the defendant, and that he lost it while making trips as an inspector. He alleged that he made formal notification of the loss and demanded payment from the defendant. Procedural History: The trial court, upon objection by the defendant, ruled that secondary evidence was inadmissible to establish ownership and loss of the ticket, citing the condition printed on the ticket: "Prizes of tickets sold locally will paid to holder of ticket upon surrender of same." The defendant presented no evidence. The court dismissed the complaint. The Petition: The plaintiff appealed, questioning the admissibility of secondary evidence.
Issue(s)
Whether secondary evidence (oral testimony) is admissible to prove the ownership and loss of a sweepstakes ticket for the purpose of claiming a prize when the ticket expressly requires surrender as a condition for payment.
Ruling
The Supreme Court affirmed the decision of the lower court, dismissing the complaint without pronouncement as to costs.
Ratio Decidendi
On Issue 1: The Supreme Court affirmed the dismissal, ruling that the surrender of the ticket is a condition precedent to the payment of the prize. The Court characterized the contract as aleatory in nature, governed by Article 1790 of the Civil Code. It emphasized that under Article 1255 of the Civil Code, contracting parties are free to establish any agreements or conditions they deem advisable, so long as they do not violate law, morals, or public order. The stipulation on the ticket requiring its surrender for payment is a valid and binding term. Citing Article 1091 of the Civil Code and the case of Hanlon v. Hausserman and Beam, the Court held that obligations arising from contracts have the force of law between the parties and must be performed according to their stipulations. Applying the precedent in Santiago v. Millar, the Court concluded that since the physical presentation of the ticket was a mandatory condition of the contract, the plaintiff could not bypass this requirement by offering secondary evidence of the ticket's loss.
Main Doctrine
The surrender of a sweepstakes ticket is a condition precedent to the payment of the prize, and secondary evidence is inadmissible to prove ownership and loss of a lost ticket.