I. The practice and why it raises legal issues

“Mandatory raffle ticket purchase” usually appears in one of these forms:

Employees are required (explicitly or through pressure) to buy a set number of raffle tickets for an office “fund-raising,” anniversary, Christmas party, team-building, or a “charity” drive.
Clients, permit applicants, bidders, suppliers, or contractors are required (openly or impliedly) to buy raffle tickets to get faster service, avoid trouble, secure approvals, or maintain “good relations.”
The office uses public funds (MOOE, trust receipts, “donations,” or collected fees) to buy tickets or underwrite prizes.
The office itself runs a raffle as a revenue-raising scheme or for a “cause,” using government time, resources, or personnel.

These practices collide with several core rules of Philippine public law: no solicitation by reason of office, no coercion, no use of public funds for non-government purposes, and no side-payments tied to government transactions.

II. Key legal principles that govern the issue

A. Public office is a public trust

The Constitution declares that public office is a public trust and public officers must serve with responsibility, integrity, loyalty, and efficiency. This principle underpins bans against solicitation, extortionate “contributions,” and using office influence to extract money.

Implication: Anything that looks like “pay-to-comply,” “pay-to-please,” or “pay because we have authority over you” is presumptively improper.

B. Prohibition on solicitation and receiving benefits “by reason of office”

Philippine law and administrative discipline regimes treat it as a serious wrong when a public officer or employee solicits or accepts money or anything of value in connection with official functions, transactions, or influence.

Mandatory raffle ticket selling becomes legally toxic when:

the person selling is a government official/employee and the purchase is tied to their position or office influence; or
the buyer is someone with business before the office (permit applicant, regulated entity, bidder, contractor, auditee, etc.); or
the “request” is not really voluntary.

This area is commonly anchored on:

Anti-Graft and Corrupt Practices Act (R.A. 3019) concepts (solicitation/receipt of benefits connected to official dealings; use of position to obtain advantage; causing undue injury or giving unwarranted benefits).
Code of Conduct and Ethical Standards for Public Officials and Employees (R.A. 6713) concepts (professionalism, justness and sincerity, responsiveness, avoiding conflicts of interest, and not soliciting/accepting gifts or benefits connected to office).
Civil Service administrative rules that treat solicitation, receiving gifts/benefits connected to duties, conduct prejudicial to the best interest of the service, and misuse of authority as punishable offenses.

Bottom line: When the “raffle ticket” functions as a thinly disguised contribution demanded because of official position, it is typically unlawful.

C. Coercion and abuse of authority

Even if a raffle is “for a good cause,” coercing payment can trigger:

Administrative liability (oppression, misconduct, abuse of authority, conduct prejudicial).
Criminal liability under coercion/extortion-type theories depending on facts (e.g., threats, withholding services, conditioning approvals, or intimidation).
Integrity/anti-red tape concerns when the payment is connected to service delivery.

A practical test: If a person reasonably believes they will suffer a disadvantage (delay, denial, retaliation, poor evaluation, lost opportunity) for refusing to buy, the purchase is not voluntary.

D. Restrictions on using public funds (and the “public purpose” requirement)

Government spending must satisfy lawful appropriation and public purpose requirements. Auditing rules generally allow only expenses that are necessary, reasonable, and directly connected to official functions.

Common audit outcomes in practice (as a principle): public funds should not be used to buy raffle tickets, subsidize private benefits, or finance social/fund-raising activities that are not authorized government programs with a clear legal basis.

Implication: An office cannot lawfully “solve” the problem by purchasing tickets using MOOE or by “reimbursing” employees.

E. Government fund-raising is not automatically authorized

A government office is a creature of law. It may only do what its legal authority permits. “Fund-raising by raffle” is not an inherent power of most agencies.

If an office conducts a raffle, issues tickets, collects money, and gives prizes, it may raise additional issues:

Authority: Does the agency have statutory authority to raise funds this way?
Handling of collections: Government receipts generally must be properly receipted, deposited, and accounted for under government accounting/auditing rules.
Use of government time/resources: Running a raffle during office hours or using government equipment may be questioned as misuse of public resources.
Gambling/lottery regulation issues: Depending on structure, an unauthorized raffle may be treated as an unlawful lottery/gambling scheme unless properly permitted/authorized.

III. Legality analysis by common scenario

Scenario 1: A government office requires its employees to buy raffle tickets

General rule: Requiring employees to buy is highly risky and often unlawful in substance because it is coercive and tied to workplace power dynamics.

Why it’s problematic:

It can be oppression/abuse of authority if superiors pressure subordinates.
It can be misconduct if the “requirement” is enforced through threats (bad performance ratings, undesirable assignments, exclusion, retaliation).
If money is collected and handled informally, it may create accountability and audit issues.
If the raffle is “for office funds,” it can resemble an unauthorized fund-raising scheme.

A narrow safer zone: Truly voluntary participation, no quotas, no tracking, no retaliation, no supervisor pressure, no use of official authority, and transparent lawful handling of any money—yet even then, the office must still confront authority/audit constraints if it is an “office project.”

Scenario 2: The office requires clients/suppliers/regulated entities to buy tickets

This is the most legally dangerous form.

General rule: Conditioning government service or favorable treatment on buying raffle tickets is strongly indicative of corruption and may fit within anti-graft and bribery-related frameworks.

Red flags:

“Buy tickets so your permit/clearance moves.”
“Every bidder must buy.”
“Contractors are assigned a quota.”
“Regulated entities are ‘requested’ to support our raffle.”
“Audited entities are asked to buy.”

Why it’s likely unlawful:

It resembles solicitation of money by reason of office.
It undermines procurement integrity and fair competition when imposed on bidders/contractors.
It can be treated as an unofficial fee or exaction, especially when tied to approvals, inspection results, or processing speed.
It can trigger administrative and criminal exposure for both the demand and the acceptance.

Scenario 3: Public funds are used to buy raffle tickets or finance prizes

General rule: This is typically disallowable and may result in:

Audit disallowance and orders to refund.
Administrative cases for officials who approved/processed the expense.
Potential graft exposure if the spending lacks legal basis and benefits private persons.

Reasoning: Raffle tickets are not a standard, necessary government expense. Using government money for speculative chances to win prizes or to support an outside raffle is hard to justify as a direct public purpose.

Scenario 4: The raffle is for a “charity” or “benefit” and everyone says it’s for a good cause

A good cause does not cure coercion or misuse of authority.

What still matters legally:

Was participation truly voluntary?
Were subordinates pressured?
Were clients or bidders targeted?
Were government resources used?
Were collections properly authorized, receipted, deposited, and audited?
Is the office legally authorized to raise and spend funds this way?

“Charity” language can reduce reputational resistance, but it does not remove legal restrictions on solicitation and public finance.

IV. Potential liabilities

A. Administrative liability (Civil Service / agency discipline / Ombudsman)

Possible charges depending on facts:

Grave misconduct / serious misconduct (corruption, clear intent to violate the law, or flagrant disregard of rules).
Conduct prejudicial to the best interest of the service.
Oppression / abuse of authority (especially superior-to-subordinate coercion).
Dishonesty (if collections or reporting are falsified).
Violation of ethical standards (solicitation/acceptance of benefits connected to office).

Penalties can range up to dismissal, forfeiture of benefits, and disqualification from public employment, depending on gravity and evidence.

B. Criminal liability (fact-dependent)

Mandatory ticket schemes can overlap with:

Anti-graft theories when officials solicit/receive benefits connected to official transactions or use position to obtain advantage.
Bribery/extortion/coercion-type offenses when there is a demand with threats, quid pro quo, or conditioning of services.
Offenses related to unlawful lotteries/gambling if the raffle structure is unauthorized and falls within definitions of illegal lottery (highly dependent on structure, authorization, and permits).

Criminal exposure depends on specific acts (who demanded, from whom, what leverage, what quid pro quo, what handling of funds, and what approvals were involved).

C. Audit and financial accountability (COA and internal auditors)

Even absent criminal prosecution, consequences may include:

Disallowance of expenses related to ticket purchases, prizes, and “office fund” spending.
Notice of Suspension/Disallowance/Charge and possible refund liability for approving and certifying officers and recipients, depending on circumstances.
Findings on improper collection/handling of funds if tickets were sold under the office name without proper authority and accounting.

V. Indicators of illegality or high risk (practical checklist)

A raffle-ticket activity is likely improper or unlawful if any of the following are present:

Quota or “required number of tickets” assigned to employees, bidders, or contractors.
Tracking lists posted publicly or monitored by supervisors.
Threats/retaliation, explicit or implied, for non-participation.
Targeting people with pending transactions in the office (permits, inspections, procurement, audit, regulation).
Use of government letterhead, email, or official channels to pressure participation as an “office directive.”
Cash collections without official receipts or unclear custody of funds.
Use of public funds to buy tickets or bankroll prizes.
Raffle framed as “support” that coincides with requests for approvals/favors.

VI. What can be lawful (and still needs care)

Some practices may be lower-risk but still require compliance with authority, accounting, and ethics rules:

Purely voluntary, personal, off-duty participation by employees in a private raffle run by an external entity, with no office pressure and no connection to official dealings.
Agency-recognized programs expressly authorized by law or formal issuance (rare), with proper accounting treatment of collections and disbursements, and strict safeguards against coercion and conflicts of interest.
Non-monetary, non-coercive internal morale activities funded through lawful means (e.g., properly authorized employee association funds that are clearly private and voluntary), while ensuring no overlap with clients/suppliers and no use of government resources beyond what rules allow.

Even in these, the “appearance of coercion” and “by reason of office” problem can arise quickly in hierarchical workplaces, so safeguards matter.

VII. Enforcement and remedies in practice (where issues are typically brought)

Complaints and findings commonly arise through:

Civil Service disciplinary processes (for national and local government employees under CSC jurisdiction).
Office of the Ombudsman (administrative and, where appropriate, criminal aspects involving public officers).
Commission on Audit (for use of public funds, collections, and disbursement irregularities).
Internal audit, grievance committees, and whistleblowing channels within agencies and LGUs.

Evidence that matters:

Written directives, memos, chat messages, quota lists.
Proof of linkage to transactions (permits, procurement, inspection).
Witness accounts of pressure, threats, or retaliation.
Money trail: who collected, where deposited, how used, whether receipted.

VIII. Conclusion

In Philippine public-sector settings, mandatory raffle ticket purchase is generally legally indefensible when it is imposed through workplace power or office influence, when directed at people with dealings before the office, or when supported by public funds. The practice commonly implicates ethical prohibitions on solicitation “by reason of office,” rules against coercion and abuse of authority, and public finance/audit requirements. Even when framed as “for charity” or “for office funds,” the decisive legal questions remain voluntariness, nexus to official functions, lawful authority, and proper accountability of funds.