Executive summary

Raffles are games of chance. In Philippine basic education, they sit at the intersection of (1) anti-gambling and charitable gaming rules, (2) consumer and local permitting rules, and (3) Department of Education (DepEd) policies on fundraising, solicitation, and child protection. When a complaint reaches the school or the Schools Division Office (SDO), the correct response is fast, documented, child-centered, and policy-anchored: pause the activity; acknowledge the complainant; verify approvals and permits; investigate facts; assess against the legal framework; decide and remediate; report to authorities; and close the loop with the complainant. This article explains the legal context and gives you a step-by-step playbook, timelines, templates, and compliance checklists.

I. Why raffle complaints matter

Risk of illegality: Unauthorized raffles can be treated as illegal gambling.
Child protection: Fundraising that pressures learners or ties rewards to ticket sales can be coercive.
Integrity and collections policy: Public schools face strict limits on fees, solicitations, and fundraising, especially during enrollment and school days.
Data privacy & reputational risk: Ticket lists, photos, and public postings expose minors’ information and the school to scrutiny.

II. Legal and policy framework (Philippine context)

Use this as an orientation map when you review a complaint. Always confirm the latest issuances applicable to your school type and locality.

Anti-Gambling & Charitable Gaming
- General prohibitions on gambling; “raffle” is typically a game of chance.
- Charitable or fundraising raffles may be allowed only with proper authority (e.g., permits/authority from competent agencies). Operating without authority risks criminal and administrative liability.
Consumer Protection / Promotions
- Raffles used to promote sales, donations, or sponsorships may qualify as promotional activities that require prior approval from competent authorities (e.g., for consumer promotions) and must follow disclosure, draw, and reporting rules. Schools rarely qualify as “promoters” for commercial promos.
Local Government & Special Permits
- Many cities/municipalities require a Mayor’s Permit/Letter of No Objection for raffles conducted within their jurisdiction, even for non-profit causes.
- Barangay endorsements may also be required by ordinance.
DepEd Policies (public and private schools)
- No unauthorized collections: Public schools are restricted from imposing fees and from soliciting money from learners/parents, especially during enrollment, without a lawful basis and documented approvals.
- Fundraising & solicitations: School-initiated fundraising must be voluntary, transparent, and never a prerequisite to access any learning activity or benefit.
- Co-curricular activities: Anything that interrupts classes, uses school time/facilities, or involves learners requires prior approvals under DepEd’s activity clearance system.
- PTA rules: PTAs have separate by-laws; fundraising must be voluntary, with SDO oversight, and must avoid learner-targeted sales pressure.
- Child Protection: Activities must avoid humiliation, coercion, or harmful competition among learners; any report of pressure or shaming is a child-protection concern.
- Gift/benefit restrictions for personnel: Solicitations by personnel may implicate ethics rules for public officials.
- Use of school name/seal: Branding requires authorization; misrepresentation can be an administrative offense.
Data Privacy
- Collecting ticket buyer lists, publishing winners, and posting photos of learners involves personal data; schools must follow data minimization, lawful basis, consent (for minors via parents/guardians), safe storage, and controlled disclosure.
Accounting & Donations
- Money and in-kind donations must be receipted, recorded, acknowledged, and used strictly for the stated purpose, with liquidation/reports available for inspection.

III. What typically triggers a DepEd complaint about raffles

Tickets sold to learners or distributed with sales quotas, or teachers urging learners to sell.
Raffle without visible permit/approval; vague mechanics.
Prizes sourced from collected funds with no transparency on costs and proceeds.
Class disruptions for ticketing or draws.
Public shaming of learners who did not buy/sell.
Use of minors’ data on public winner lists or social media.
Raffle promoted as “school-sanctioned” when it was a PTA or third-party initiative without proper coordination.

IV. Immediate response plan (first 72 hours)

Secure and pause
- Issue a written hold/cease memo to stop ticket selling/draws while under review.
- Secure boxes, stubs, ticket logs, mechanics, receipts, artwork/posts, and chat threads (preserve evidence).
Acknowledge the complaint (within 24–48 hours)
- Send a neutral, non-adversarial acknowledgment to the complainant with a target date for a substantive response and a contact person (usually the school head or designated complaints focal).
Conflict-check & recusal
- If the school head or a staff member is involved, elevate to the SDO and consider assigning an Investigating Committee to avoid conflict of interest.
Notify superiors
- Inform the Schools Division Superintendent (SDS) through the division legal/complaints unit. If the complaint came via the DepEd Action Center or Regional Office, mirror their tracking number.
Risk triage
- If children were pressured, shamed, or harmed: trigger child-protection protocols immediately and provide psychosocial support.
- If funds changed hands: freeze collections, open a trust account/log, and prevent further disbursements.

V. Internal fact-finding: what to collect

Authority trail: resolutions (e.g., from SGC/SSC/PTA), school head approval, SDO clearances, LGU/agency permits, venue consent, mechanics, draw procedures, and publicity materials.
Money trail: printouts of ticket series, stubs, collectors’ logs, cash receipts, bank deposits, expense vouchers, prize purchase invoices, liquidation drafts.
Child-safety trail: advisories to parents, consent forms, class advisories, teacher instructions; homeroom chat messages.
Operational trail: who printed tickets, who sold, where kept; lists of winners and non-participants (if any), and how announcements were made.
Data privacy trail: privacy notices, consent for publishing names/photos, retention plans.

Interview discreetly: complainant (if willing), teacher/adviser, PTA officers, designated treasurer, and student leaders—without interrogating learners.

VI. Legal analysis checklist (apply systematically)

Nature of activity
- Is it a game of chance with consideration (payment)? If yes, it is a raffle subject to permits/authority.
- If no payment and purely token entries, treat as a contest—still needs approvals if during school hours or using facilities.
Authority & permits
- Does the school (or PTA/third party) hold valid, activity-specific approvals?
- Do permits match the jurisdiction, dates, mechanics, prizes, and organizer’s legal identity?
DepEd/School governance
- Was there SDO-level clearance if required?
- Was the activity voluntary for learners and parents? Any direct/indirect pressure?
- Did it interrupt classes or use instructional time?
Child protection
- Any acts of shaming, coercion, or retaliation?
- Were vulnerable learners (e.g., those who declined) protected?
Financial propriety
- Are collections receipted and deposited intact?
- Are expenses reasonable, prizes procured properly, and liquidation prepared?
- Is there segregation of duties (seller ≠ custodian ≠ approver)?
Data privacy
- Was personal data minimized? Were minors’ names/photos published with parental consent and lawful basis?
- Is there a retention/disposal plan?
Communications integrity
- Were mechanics and odds disclosed? Are winner lists accurate and verifiable?
- Any misleading claims (“DepEd-approved!”, “mandatory!”)?

VII. Decision tree & remedies

Case A — Unauthorized/defective raffle
- Terminate the activity; void the draw.
- Refund collections where feasible or convert to permissible donations with written donor consent.
- Confiscate/secure remaining tickets; inventory.
- Corrective actions: staff coaching, formal reprimand, or administrative referral per due process.
- Report outcome to SDO and (if required) to LGU/concerned agency.
Case B — Procedurally valid but child-protection issues
- Cease any learner-targeted selling.
- Remove incentives/penalties tied to ticket sales.
- Counsel involved staff/volunteers.
- Issue a child-safe messaging advisory; update homeroom guidance.
Case C — Valid with minor lapses
- Proceed only after curing defects (e.g., missing disclosures, signage, privacy notice, transparent winner verification).
- Reschedule draw if timelines/permits need alignment.
Case D — Frivolous complaint
- Close with a reasoned explanation and attach documentary proof of compliance; retain an investigation file.

VIII. Timelines (good-practice benchmarks)

Acknowledgment to complainant: within 2 business days.
Preliminary report to SDO: within 5 business days of receipt.
Final determination & remediation: within 15 business days, unless complexity requires more time (explain and update).

IX. Writing the responses (templates)

1) Acknowledgment (to complainant)

Subject: Your complaint regarding the [date] raffle activity

Good day. We received your complaint on [date] concerning the raffle conducted by [School/Organizer]. We have paused the activity while we review permits, learner safeguards, and financial records. We aim to provide a substantive update by [date]. You may reach [Name/Position, contact] for any additional information you wish to share.

Thank you for helping us ensure a safe and lawful learning environment.

2) Notice of Hold (internal)

Effective immediately, all activities related to the [name of raffle] are paused pending compliance review. Custodians shall secure tickets, stubs, funds, and records. No further selling, announcements, or draws may be conducted without written clearance.

3) Substantive Reply (to complainant)

We completed our review on [date]. The raffle was [authorized/unauthorized]. Findings: [brief bullet points on permits, voluntariness, child-safety, finances, data privacy]. Actions taken: [terminate/refund/discipline/rectify/report]. Preventive measures: [policy refresher, approvals protocol, prohibition on learner-targeted selling, privacy controls].

If you have further concerns, you may contact [SDO/Regional office contact]. Thank you for raising this matter.

X. Documentation & reporting package (what to compile)

Complaint intake form; acknowledgment; pause memo.
Approvals/permits; mechanics; publicity materials.
Ticket series inventory; sales logs; deposit slips; prize invoices; liquidation.
Interview notes; screenshots; photos; chat exports (redacted).
Data privacy notices/consents; publication proof and corrections.
Final report with findings, legal analysis, actions, and recommendations.
Transmittal to SDO and any external authority (if required).

XI. Preventive controls for future activities

Default rule: no learner-targeted raffles. If fundraising is necessary, design adult-only activities through the PTA or alumni, outside class hours and off campus where possible.
Always secure written approvals before printing tickets or posting online.
Voluntariness and non-retaliation must be explicit in all communications. Never link participation to grades, requirements, or privileges.
Publish clear mechanics: draw date/time/location, verification process, treatment of unclaimed prizes, and complaint channel.
Two-person control on custody of tickets and funds; daily reconciliation; bank deposit within 24 hours above a set threshold.
Privacy by design: avoid publicizing minors’ full names; use initials or student numbers when feasible; get parental consent for any photo publication.
Train staff and PTA officers annually on DepEd rules, child protection, and financial controls.
Use non-chance alternatives: fun runs, benefit shows, goods/services fairs, sponsorships—designed to be voluntary and educational.

XII. Common pitfalls (and how to avoid them)

“PTA did it, so school rules don’t apply.” Wrong—school-related fundraising with learners involved still triggers DepEd oversight and child-protection rules.
“We’ll fix the permit later.” Post-facto curing rarely works for games of chance.
“Winners must be posted publicly with full details.” Minimize personal data—publish only what’s necessary.
“It’s for a good cause, so it’s okay.” Good intent does not replace legal authority or learner safeguards.
“Only teachers handled the money.” That can worsen accountability; segregate roles and keep audit trails.

XIII. Administrative due process for personnel (if implicated)

Show-Cause Order specifying acts/omissions and rules allegedly violated.
Written explanation within the prescribed period; offer of hearing if facts are contested.
Evaluate evidence against substantial-evidence standard; apply proportional sanctions (coaching → reprimand → suspension/charges), considering mitigating factors (good faith, lack of training, immediate corrective action).
Document everything; provide the employee a copy of the decision and remedies.

XIV. Quick compliance checklist (printable)

Activity paused; evidence preserved
Complaint acknowledged within 2 days
SDO notified; investigator designated
Authority trail verified (school/SDO/LGU/agency)
Voluntariness & child-safety confirmed
No learner-targeted selling or class disruption
Financial records complete; segregation of duties
Data privacy notices/consents in place
Findings documented; decision issued
Complainant informed; preventive measures adopted

XV. Final notes

Treat every raffle complaint as both a compliance and a child-protection matter.
When in doubt, err on the side of pausing and shifting to non-chance, voluntary, adult-focused fundraising models.
Always cross-check the latest DepEd, local government, and relevant agency rules before conducting any raffle-type activity.