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Caltex Inc. vs. Palomar CASE DIGEST

This case digest summarizes the case of Caltex Inc. vs. Palomar, which involved a promotional contest held by Caltex Philippines to increase patronage of its oil products. The Postmaster General denied Caltex's request to clear the contest, believing it violated anti-lottery laws. Caltex sought declaratory relief. The court ruled that a justiciable controversy existed between the adverse parties, and that judicial decisions have the force of law in the Philippines legal system under Article 8 of the Civil Code. The court's ruling in this case would be binding and help resolve the differences between Caltex and the Postmaster General.

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379 views2 pages

Caltex Inc. vs. Palomar CASE DIGEST

This case digest summarizes the case of Caltex Inc. vs. Palomar, which involved a promotional contest held by Caltex Philippines to increase patronage of its oil products. The Postmaster General denied Caltex's request to clear the contest, believing it violated anti-lottery laws. Caltex sought declaratory relief. The court ruled that a justiciable controversy existed between the adverse parties, and that judicial decisions have the force of law in the Philippines legal system under Article 8 of the Civil Code. The court's ruling in this case would be binding and help resolve the differences between Caltex and the Postmaster General.

Uploaded by

Rica Dominguez
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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PERSONS AND FAMILY RELATIONS | CASE DIGEST

Caltex Inc. vs. Palomar 18 SCRA 247

Judicial Decisions (Article 8 of the Civil Code)

FACTS:
● In the year 1960, Caltex Philippines conceived a promotional scheme calculated to
drum up patronage for its oil products.
● The contest was entitled “Caltex Hooded Pump Contest '', which calls for participants
to estimate the actual number of liters, a hooded gas pump at each Caltex station will
dispense during a specific period.
● Foreseeing the extensive use of the mails through the media for publicizing the
contest and also for the transmission of communications, representations were made
by Caltex with the postal authorities for the contest to be cleared in advance for
mailing.
● This was formalized in a letter sent by Caltex to the Postmaster General, dated
October 31, 1960, in which Caltex, thru its counsel, enclosed a copy of the contest
rules and endeavored to justify its position that the contest does not violate the “The
Anti-Lottery Provisions of the Postal Law”.
● Unfortunately, the Palomar, the acting Postmaster General denied Caltex’s request
stating that the contest scheme falls within the purview of the Anti-lottery Provision and
ultimately, declined Clatex’s request for clearance.
● Caltex sought reconsideration, stressing that there being no consideration involved in
part of the contestant, the contest was not commendable as a lottery.
● However, the Postmaster General maintained his view that the contest involves
consideration, or even if it does not involve any consideration it still falls as “Gift
Enterprise”, which was equally banned by the Postal Law.

ISSUE:

Whether or not the scheme proposed by Caltex the appellee is within the coverage of
the prohibitive provisions of the Postal Law?

RULING:

By express mandate of Section 1 of Rule 66 of the old Rules of Court which deals with the
applicability to invoke declaratory relief which states: “Declaratory relief is available to person
whose rights are affected by a statute, to determine any question of construction or validity
arising under the statute and for a declaration of rights thereunder.

In amplification, conformably established jurisprudence on the matter, laid down certain


conditions:

1. There must be a justiciable controversy.


2. The controversy must be between persons whose interests are adverse.
3. The party seeking declaratory relief must have a legal interest in the controversy.
PERSONS AND FAMILY RELATIONS | CASE DIGEST

4. The issue involved must be ripe for judicial determination.

With the appellee’s bent to hold the contest and the appellant’s threat to issue a fraud order if
carried out, the contenders are confronted by an ominous shadow of imminent and inevitable
litigation unless their differences are settled and stabilized by a declaration. And, contrary to
the insinuation of the appellant, the time is long past when it can rightly be said that merely
the appellee’s “desires are thwarted by its own doubts, or by the fears of others” — which
admittedly does not confer a cause of action. Doubt, if any there was, has ripened into a
justiciable controversy when, as in the case at bar, it was translated into a positive claim of
right which is actually contested.

The appellant underrates the force and binding effect of the ruling in this case if. He believes
that it will not have the final and pacifying function that a declaratory judgment is calculated to
subserve. At the very least, the appellant will be bound. But more than this, he obviously
overlooks that in this jurisdiction, "Judicial decisions applying or interpreting the law shall form
a part of the.legal system" (Article 8, Civil Code of the Philippines).

In this jurisdiction,​ judicial decisions​ assume the same authority as the statute itself and,
until authoritatively abandoned, necessarily become, to the extent that they are applicable, the
criteria which must control the actuations not only of those called upon to abide thereby but
also of those in duty-bound to enforce obedience thereto.

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