Petitioner
Alejandro Reyes
Respondent
Francisco Martinez
Citation
G.R. No. 1724
Court
Supreme Court En Banc
Division
En Banc
Ponente
Johnson, J.
Decided
December 11, 1905

Summary

This 1905 case involved the enforceability of a promissory note executed for gambling debts. Francisco Martinez issued a 1,200-peso promissory note to Alejandro Reyes for money lost playing 'burro,' a Filipino card game. The trial court ruled the debt unenforceable, considering 'burro' a prohibited game of chance under Article 1798 of the Civil Code. The Supreme Court reversed, finding that 'burro' is a game of skill rather than pure chance, since players can discard and exchange cards based on strategy. The Court distinguished games of chance (which depend exclusively on luck) from games involving skill and player choice. Since 'burro' requires skill and is not prohibited by law, the promissory note was enforceable, establishing an important precedent regarding the enforceability of gambling debts in skill-based games.

Statutes applied

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By the Intellegal Editorial Board · December 11, 1905

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