GR No.

L-7140

Dec 22, 1955



The People of the Philippines, plaintiff- appellee
vs.
Esteban Zeta, defendant- appellant

LABRADOR, J.:



FACTS:



This is an appeal of judgement of the court of First Instance of Samar, finding Zeta (defendant) guilty of violating
RA 145 for collecting P300 from Eugenio Albiza for helping him claim his benefits under the law of the United
States.



Eugenio Albiza is a member of the Philippine Army and later the United States Armed Forces in the Far East. He got
disabled while on service in Aparri, Cagayan in 1942. On November 6, 1946 he promised Zeta 5% of whatever he
will receive as a result of his claim, for Zeta’s services.



In pursuance of the contact, he paid Zeta the 5% of the amount he received and that was, P200 on June 7, 1951 and
P100 on June 11, 1951, as prescribed in Sec 11 of Common wealth Act No. 675 which was in effect at that time.



On June 14, 1947, RA No 145 was passed. Consequently, on June 1951, Albiza Received his benefits and paid
respondent pursuant of the contract between them.

The trial Court held that upon passage of the RA No 145, the agreement of 5% was voided and compliance will
become illegal. So it sentenced respondent to pay a fine of P200, to indemnify Albiza in the sum of P280 , or suffer
subsidiary imprisonment in case of insolvency and to pay the cost.


ISSUE:



Whether or not RA 145 shall retroact to the act of Zeta prior to it’s passage



Held:



No. The Supreme Court Held that legislature had not intended to give RA 145 retroactive effect such as to affect the
contracts entered under the sanctions of the previous law which is Commonwealth Act 675. 



Also, generally, there is a presumption that all laws operate prospectively only and only when the legislative has
clearly indicated it’s intention that the law operate retroactively will the courts so apply it.

Statutes should not be interpreted in a manner that would render its application violative of a constitutional
inhibition. Strict construction to prevent retroactive operation has
often been applied in order that the statute would not violate contract obligations or interfere with
vested rights. The principal explanation offered by the court is that statute must me be construed so as to sustain its
constitutionality and thus prospective operation will be presumed where a retroactive operation would
produce invalidity.


The judgment appealed from is hereby reversed and the defendant-appellant acquitted with costs de officio.