A.C. No. 5364 - Manaois vs. Deciembre

The People of the Philippines, as Plaintiff and Appellee, versus Esteban Zeta, as Defendant and Appellant.
The case is an appeal from the judgment of the Court of First Instance of Samar which found Zeta guilty of violating Republic Act No. 145.

Esteban Zeta allegedly assisted Eugenio Albiza, an enlisted man of the Philippine Army (and later, USAFFE), in preparing, presenting, and prosecuting his claim for benefits under the laws of the United States.
An agreement was executed on November 6, 1946, wherein Albiza promised to pay Zeta 5 percent of any monetary benefits recovered from his claim.
Zeta prepared necessary documents for disability compensation, leading to Albiza receiving P5,919 from the United States Veterans Administration.
Subsequently, Albiza made partial payments to Zeta: P200 on June 7, 1951 and P100 on June 11, 1951 in accordance with the agreement.

At the time the contract was executed, the applicable law was Commonwealth Act No. 675, Section 11.

This provision limited the fee for services rendered to a maximum of 5 percent of the total arrears in pay and allowances.
It also provided that fees would only become due and demandable after the payment of the said arrears, and unauthorized deductions were prohibited.
Violation of this section stipulated penalties including imprisonment or a fine, or both.

Republic Act No. 145 was enacted on June 14, 1947, after the original contract was entered into.
RA 145 imposed a new standard:

It penalized any person assisting in claims for US benefits who, directly or indirectly, solicited, charged, or received any fee exceeding twenty pesos per claim.
It also prohibited the collection of such fees before the actual payment of benefits to the claimant or beneficiary.
Penalties under RA 145 included fines up to one thousand pesos and/or imprisonment of up to two years.

The trial court found that after the passage of RA 145, the agreement for a 5 percent fee became void and its performance illegal.
The defendant-appellant, Esteban Zeta, was sentenced:

To pay a fine of P200.
To indemnify Eugenio Albiza with F280, or face subsidiary imprisonment if insolvent.
To bear the costs of the proceedings.

The defendant-appellant contended that applying RA 145 to his case violated the constitutional prohibition against ex post facto laws.
He argued on the basis of precedent (citing the case of U.S. vs. Diaz Conde) that a law must be construed prospectively so that contracts valid at their inception are not impaired retroactively.
However, it was noted that, distinct from the cited case, the fee in this instance was collected after the enactment of RA 145, while the services were rendered before its effect.

Whether the imposition of RA 145 on fees collected after its enactment, despite the underlying contract having been executed under Commonwealth Act No. 675, violates the constitutional prohibition against ex post facto laws.
Whether applying RA 145 retroactively impairs contractual rights that were valid and sanctioned under the previous law.

Whether RA 145 should be interpreted as operating only prospectively.
Whether the legislature intended to affect contracts that had accrued their rights under the provisions of Commonwealth Act No. 675.