It could be many things, but you're probably best off treating it like edema (which it could be; if it's not edema, it probably would contribute to it a lot, if conditions were favorable for edema). I've had that issue when starting tomatoes indoors under lights. I've never had it with other methods of starting them.
I would suggest such as the following: increasing ventilation, reducing temperatures, don't get the leaves wet when you water, give them extra potassium, etc. For me, the issue went away after the transplant, with the new growth.
If your plant is already in its final destination, I might suspect humidity being the issue. I wouldn't worry about it too much, unless something else starts to happen.
Possibilities (besides edema) include things like mites, scale insects, downy mildew, parasitic algae, etc.
It's not sun damage, but those areas could be more prone to sun damage in future.
I don't think it's leaf miners.