GR L 7140; (December, 1955) (Digest)
G.R. No. L-7140 December 22, 1955
People of the Philippines vs. Esteban Zeta
FACTS
Esteban Zeta was convicted by the Court of First Instance of Samar for violating Republic Act No. 145 . The charge stemmed from his having solicited, charged, demanded, and collected a fee of P300 from Eugenio Albiza for assisting in the preparation, presentation, and prosecution of Albiza’s claim for disability benefits from the United States Veterans Administration. On November 6, 1946, Albiza promised in writing (Exhibit 1) to pay Zeta 5% of any amount received from his claim. Zeta prepared the necessary papers, and Albiza subsequently received P5,919. In accordance with their agreement, Albiza paid Zeta P200 on June 7, 1951, and P100 on June 11, 1951. At the time the agreement was executed, Commonwealth Act No. 675 was in force, which permitted fees up to 5% of the total arrears, payable only after the claimant received payment. Republic Act No. 145 took effect on June 14, 1947, which made it illegal to charge or receive any fee exceeding twenty pesos for such services. The trial court held that the agreement was voided by the new law and convicted Zeta.
ISSUE
Whether Republic Act No. 145 can be applied retroactively to penalize Zeta for collecting a fee under an agreement that was legal and expressly sanctioned by Commonwealth Act No. 675 at the time it was made.
RULING
The Supreme Court reversed the judgment of conviction and acquitted Esteban Zeta. The Court held that Republic Act No. 145 must be given prospective application only and cannot be applied retroactively to affect rights that had already accrued under a contract expressly permitted by a previous law ( Commonwealth Act No. 675 ). The presumption is that laws operate prospectively unless the legislative intent for retroactivity is clear. Applying the new law to Zeta’s case would be arbitrary and unreasonable, as it would impair the obligations of a contract and deprive him of a fee for services already rendered, which was a right that accrued upon the rendition of those services. Such an application would be repugnant to justice and destructive of the inviolability of contracts, and could not have been the legislative intent.