In the Philippines, the conduct of sales promotions, including raffle draws, is strictly regulated by the Department of Trade and Industry (DTI) under the authority of Republic Act No. 7394, otherwise known as the Consumer Act of the Philippines. To ensure transparency and protect the interests of the consuming public, the DTI has established specific protocols regarding the selection and validation of "Official" and "Buffer" winners.

1. Defining the Roles

In any DTI-registered promotion, winners are categorized to ensure that prizes are actually awarded even if the primary winner is disqualified or unreachable.

Official Winner: The individual whose name is first drawn for a specific prize category. They have the primary right to the prize, provided they meet all eligibility requirements set forth in the mechanics.
Buffer Winner: Also known as a "back-up" or "reserve" winner. These individuals are drawn immediately after the official winner to serve as replacements in case the official winner is disqualified.

2. The Requirement for Buffer Winners

Under DTI guidelines, specifically DTI Administrative Order No. 2, series of 1993, it is standard practice (and often a requirement during the permit application) to draw buffer winners.

The "Nine-to-One" Rule

While the exact number can vary based on the scale of the promo, the DTI generally suggests or requires a specific ratio of buffer winners for every official winner.

Typically, two (2) to nine (9) buffer winners are drawn for every one (1) official winner.
These names are drawn in a specific sequence (e.g., 1st Buffer, 2nd Buffer) to establish a clear "line of succession."

3. The Presence of a DTI Representative

For a draw to be legally binding and for the selection of official and buffer winners to be recognized, a DTI Representative must be present (either physically or virtually) to witness the proceedings.

The representative validates the entries.
They sign the Minutes of the Draw, which lists the official winners and their corresponding buffer winners in the exact order they were picked.
Without the signature of a DTI representative on the official results, the selection of buffers cannot be used to replace an official winner.

4. Conditions for Replacing an Official Winner

A buffer winner does not automatically gain a right to the prize. They only ascend to "Official Winner" status if the person drawn before them is disqualified based on the following DTI-sanctioned grounds:

Ineligibility: The official winner is an employee of the sponsor company, their advertising agency, or a relative within the second degree of consanguinity or affinity (a standard exclusion in Philippine promos).
Failure to Verify: The official winner cannot provide the required identification or the winning proof of purchase (e.g., a physical scratch card or official receipt).
No Response: The winner fails to claim the prize within the 60-day period from receipt of registered mail notification, as mandated by the Consumer Act.
Voluntary Waiver: The official winner formally refuses the prize.

5. Sequence of Succession

The transition from buffer to official status must follow a strict chronological order:

If the Official Winner is disqualified, Buffer Winner #1 is notified.
If Buffer Winner #1 is also found ineligible or fails to claim, the prize moves to Buffer Winner #2.
This process continues until the list of buffers for that specific prize is exhausted.

6. Exhaustion of Buffer Winners

If the official winner and all designated buffer winners are disqualified or fail to claim the prize, the sponsor cannot simply pick a new winner privately.

Redraws: If the pool of winners is exhausted, the company must conduct a Redraw under the supervision of a DTI representative.
Unclaimed Prizes: If the prize remains unclaimed after all legal windows (including notifications to buffers) have closed, the sponsor must notify the DTI. With DTI approval, unclaimed prizes are often forfeited in favor of the government or disposed of according to the DTI’s direction (often through donation or inclusion in a future promo).

7. Documentation and Transparency

The DTI requires that the names of both official and buffer winners be kept on file. In cases of disputes, the List of Winners submitted to the DTI serves as the final legal basis for who is entitled to a prize. Sponsors are prohibited from skipping a buffer winner to favor a subsequent name on the list; doing so constitutes a violation of the terms and conditions of the permit and can lead to administrative fines or the revocation of the company’s permit to conduct future promotions.