G.R. No. L-8404 & L-7832, January 29, 1913
AGUSTIN J. DE MONTILLA vs. LA CORPORACION DE PP. AGUSTINOS CALZADOS, etc. and FLORENTINA ANCAJAS vs. DIONISIO JAKOSALEM, SHERIFF ET AL.

FACTS

Two consolidated cases raised the issue of the official language to be used in Philippine courts. In G.R. No. L-8404, the defendant-appellant moved to strike the plaintiff-appellant’s brief from the record because it was written in Spanish, “not written in the official language.” In G.R. No. L-7832, a motion was filed to vacate a judgment of the Supreme Court because it was written in Spanish. Both the brief and the judgment were filed or rendered in actions that commenced before January 1, 1913. The motions relied on Act No. 1946 , which amended Section 12 of the Code of Civil Procedure to provide that the official language of all courts and their records would be Spanish only until January 1, 1913, and English thereafter.

ISSUE

Whether Act No. 1946 , which designated English as the official language of the courts after January 1, 1913, applies retrospectively to actions and proceedings begun prior to that date.

RULING

No. Act No. 1946 applies only prospectively to actions and proceedings commenced on or after January 1, 1913. It does not apply retrospectively to actions begun before that date.

The Supreme Court applied the well-established rule of statutory construction that all statutes are to be construed as having only prospective operation unless the legislature’s intent to give them retrospective effect is expressly declared or necessarily implied from the language. In case of doubt, the doubt must be resolved against retroactivity. The Court cited numerous authorities, including Reynolds vs. M’Arthur and United States vs. American Sugar Co., which emphasize that laws look forward, not backward, and should not be construed retrospectively unless the language renders such construction indispensable.

The Court examined Act No. 1946 and found no express words or implied intention giving it retrospective effect. Its clear intendment was prospective. While courts may be more liberal in interpreting procedural laws retrospectively, the Court found no sufficient reason to relax the rule here, as doing so could cause serious inconvenience and potentially prejudice substantial rights.

Therefore, the motions were denied. The Spanish-language brief in G.R. No. L-8404 and the Spanish-language judgment in G.R. No. L-7832, both pertaining to actions begun before January 1, 1913, were valid.