An investigation team from the DOJ and the National Bureau of Investigation also looked into claims of bribery involving Okada and Rodolfo Soriano, a former consultant of the Philippine gaming regulatory agency, but could not prove the allegations, it said.
The "facts and evidence gathered thus far are insufficient to justify the filing of bribery charges," the Justice department said in a formal statement after making public the investigation report submitted last month to Justice Secretary Leila de Lima.
The payments are also being investigated by the Federal Bureau of Investigation for potential violations of anti-bribery laws.
The investigating panel found evidence the companies set up by Okada and his associates "were actually dummies or fronts for Universal Entertainment, meant to circumvent or evade laws of nationalization of certain rights, franchises or privileges," the DOJ statement said.
Okada controls Universal Entertainment Corp.
Under the constitution and public land act, only Filipinos, or entities owned at least 60 percent by Filipino citizens, are allowed to own land, thus restricting Okada or his majority-owned companies to just 40 percent ownership.
The investigating panel said it found Okada, eight of his Japanese associates and 17 Filipinos, including Soriano and some of Okada's lawyers, all liable to charges of violating the anti-dummy law.
Ten companies controlled by Okada and Soriano were also among those recommended to face criminal charges. The cases were referred to state prosecutors for preliminary investigation prior to formal charges in court.
Universal could not immediately be reached for comment. But it has said in the past it conducted its business in the Philippines lawfully. In May, it said it acquired the land after a prominent Philippine law firm "advised us that it was legal, so this should not be an obstacle to the opening of business in the Philippines.
Universal has filed a defamation suit against Reuters in Tokyo for its reporting on the payments.
(Reporting by Manuel Mogato in Manila and Nathan Layne in Tokyo; Editing by Rosemarie Francisco and Raju Gopalakrishnan)