Case Summary (G.R. No. 2935)
Petitioner and Respondent
• Petitioner: George I. Frank (on appeal)
• Respondent: Government of the Philippine Islands
Key Dates
• April 17, 1903 – Execution of a two-year employment contract in Chicago
• April 30, 1903 – Commencement of service; half-salary paid through June 4, 1903
• June 4, 1903 – Arrival in the Philippine Islands
• February 11, 1904 – Defendant terminates service and refuses further performance
• December 3, 1904 – Government files suit in the Court of First Instance, Manila, to recover $269.23
• September 5, 1905 – Trial court enters judgment for $265.90 in favor of the Government
• October 12, 1905 – Bill of exceptions filed in the Supreme Court
• December 5, 1905 – Appellant’s brief filed
• January 19, 1906 – Attorney-General’s brief filed
• January 30, 1909 – Supreme Court requests prosecution of appeal or dismissal
• February 2, 1909 – Appeal heard
• March 23, 1909 – Supreme Court decision
Applicable Law
• Contract formation and validity: Governed by the law of the place where made (Illinois law)
• Performance and remedies: Governed by the law of the place of performance (Philippine Islands)
• Organic Act of August 29, 1902 (Act of Congress of 1902), § 5: Prohibits the Philippine legislative department from altering contract terms
• Conflict-of-laws principles: Matters of execution, interpretation, and validity by lex loci contractus; matters of performance by lex loci solutionis; remedies and procedure by the law of the forum
Facts
- The Government hires Frank as a stenographer for two years at $1,200 per annum plus prepaid travel expenses and half-salary during travel.
- Contract stipulates that violation by Frank makes him liable for travel expenses and half-salary.
- Frank begins service April 30, 1903, receives half-salary until arrival June 4, 1903.
- On February 11, 1904, Frank abandons the service and refuses further performance.
- The Government sues on December 3, 1904, claiming $269.23 for travel expenses and half-salary.
- Frank pleads general denial and two special defenses: amendment of incorporated laws (Nos. 80 and 224) altered the contract; and infancy (under Philippine law, majority at age 23).
- The trial court sustains the Government’s demurrer to the special defenses, finds Frank owed $3.33, and awards $265.90 to the Government.
Issues
- Whether subsequent amendments to Laws Nos. 80 and 224 altered the contract terms incorporated by reference.
- Whether Frank’s alleged infancy under Philippine law bars enforcement of the contract.
Ruling
The Supreme Court affirms the lower court’s judgment in favor of the Government for $265.90, with costs.
Reasoning
• Legislative Amendments: Section 5 of the Organic Act of 1902 bars the Philippine legislative department from modifying existing contract terms. The amendments to Laws Nos. 80 and 224 thus did not alter the parties’ binding agreemen
Case Syllabus (G.R. No. 2935)
Procedural History
- Judgment rendered below on September 5, 1905, in the Court of First Instance of Manila in favor of plaintiff.
- Defendant appealed; filed printed bill of exceptions on October 12, 1905, and his brief on December 5, 1905.
- Attorney-General filed appellee’s brief on January 19, 1906.
- After inactivity, this Court, on January 30, 1909, requested prosecution of the appeal or dismissal.
- Appellant petitioned to place the cause on the Supreme Court calendar; argued on February 2, 1909.
Facts of the Case
- On April 17, 1903, in Chicago, Illinois, appellant contracted with the Insular Government of the Philippine Islands to serve as stenographer for two years at US$1,200 per annum.
- Contract provided for advance payment of travel expenses from Chicago to Manila and one-half salary during travel.
- Appellant began performance on April 30, 1903; received half-salary until arrival in Manila on June 4, 1903.
- On February 11, 1904, appellant left service and refused further contract performance.
- Plaintiff sued on December 3, 1904, to recover US$269.23 expended by way of travel expenses and half-salary.
Contract Provisions
- Two-year term with annual salary of US$1,200.
- Advance payment of travel expenses from Chicago to Manila.
- Payment of one-half salary du