Massa had more race wins in 2008
FIA confirm 2009 season based on wins rather than points

Felipe Massa on the podium at the Brazilian Grand Prix 2008. The FIA have today announced that the 2009 season will see race wins count above any points scored towards the driver's championship. If two drivers end the year on the same tally of wins, then points come into play. In 2008, Massa had more race wins than Hamilton and would have been World Champion.