Associate Justice Amy Lazaro-Javier of the Philippine Supreme Court filed a dissenting opinion in G.R. No. 207118 on April 22, 2025, taking the position that bingo is a game of chance under the jurisdiction of the Philippine Amusement and Gaming Corporation (PAGCOR), and that Presidential Decree No. 1869, as amended by Republic Act No. 9487, takes precedence over the Local Government Code1.
The case concerns "Bingo sa Barangay," a program that allows barangays, the smallest local government units in the Philippines, to conduct bingo as a fund-raising activity. Lazaro-Javier joined the position of Justice Alfredo Benjamin S. Caguioa that the majority opinion "cannot rely on Section 391(a)(11) of the Local Government Code as basis [to justify 'Bingo sa Barangay'], as this only authorizes barangays to conduct 'fund-raising activities'"1.
Lazaro-Javier wrote that PAGCOR has been the administrative agency charged with centralizing and integrating the right and authority to operate and conduct games of chance since 1983, and that it has been regulating games of chance for more than 41 years1. She invoked the doctrine of lex specialis derogat generali, holding that Presidential Decree No. 1869, as amended by Republic Act No. 9487, is specially designed to govern games of chance, including bingo, while the Local Government Code is geared toward local autonomy and decentralization1.
"All games of chance, like bingo, are under the jurisdiction of PAGCOR"
She proposed a clear delineation: all games of chance, like bingo, fall under PAGCOR's jurisdiction, while other fund-raising activities that are not games of chance fall within the jurisdiction of local government units, subject to Section 391(a)(11) of the Local Government Code1. She also wrote that bingo is by definition a game of chance, and that its incidental use as a fund-raising activity does not change its true nature1.
The dissenting opinion was filed alongside the majority decision by Justice Marquez, a concurring opinion by Justice Leonen, and separate dissenting opinions by Justices Caguioa, Inting, and Singh1. The full text of the majority decision and the other opinions was not included in the source pages, so the reasoning of the majority and the specific outcome of the case have not been reported here.
What it means for players
The practical effect for people who play bingo in the Philippines depends on which opinion the Court ultimately follows. If the majority decision upholds barangay-run bingo under the Local Government Code, then community bingo sessions organized by barangays would remain outside PAGCOR's direct regulatory control. If the position taken by Lazaro-Javier prevails, bingo would be classified as a game of chance under PAGCOR's jurisdiction regardless of whether it is run as a fund-raiser, which would place barangay bingo under the national gaming regulator's rules. The dissenting opinion does not change the outcome of the case on its own. Players in the Philippines can read more about the regulatory landscape in the Philippines gambling guide and the overview of gambling laws across Asia.
What happens next
The dissenting opinion was filed on April 22, 2025. No further steps, such as motions for reconsideration or enforcement directives, have been reported in the source pages.
Sources1 sources
- G.R. No. 207118 - Dissenting Opinion, lawphil.net
