People of the Philippines vs. E. Zeta G.R. No.

L-7140 December 22, 1955 En Banc Facts: The petitioner in this case was accused of violation RA 145 which was passed a year after he initiated an action to assist a certain Eugenio Albiza who was a member of Philippine Armed Forces and later on of United States Armed Forces in the Far East. The latter suffered disability while in service in 1942 and in 1946 the respondent and Eugenio had an agreement that Eugenio will pay the respondent 5% of any amount he could get as prescribed in Sec. 11 of Commonwealth Act. No. 675 which is in effect at that time. On June 14, 1947 RA 145 was passed and on June 1951 Eugenio Albiza received his benefits and as he and the respondent agreed before, he paid the respondent pursuant to their contract. The respondent was then prosecuted for Violation of RA 145. Issue: Whether or not RA 145 shall retroact to the act of the respondent prior its passage. Ruling: No. The Supreme Court held that the legislature had not intended to give RA 145 any retroactive effect such as to affect contracts entered into under the sanction of the CA No. 675. It further stated that in general, law operate prospectively only unless that legislative has clearly indicated its intention that the law operate retroactively. Statutes should not be interpreted in a manner that would render its application violative of a constitutional inhibition. The court stated that 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 is hereby reversed and the defendant-appellant was acquitted.