Gov’t of the Phil. Island vs George I.

Frank

G.R. No. L-2935, 23 March 1909

Johnson, J.

Facts:

Through a contract executed in the US, Frank agreed to work for Plaintiff in the
Philippines. The plaintiff paid Frank an advance payment upon arriving in the Philippines
as stipulated in their contract.

While in the Philippines Frank left the service of the Government. Since Frank
abandoned the contract, the Government filed a case against him to collect the remaining
money that was paid in advanced.

Frank in his defense contends that he was an adult in the US but he is a minor in the
Philippines.  So the contract cannot be enforced against him.

The lower court decided in favor of the plaintiff and ordered the defendant to pay the
amount in question.

Issue:

Whether or not the court was correct in rendering judgment in favor of the plaintiff.

Ruling:

Yes. The contention of the defendant that he is an adult in the US but  he is still a minor
in the Philippines where the contract was implemented is not disputed.  In fact the court
considered the defendant’s contention as a reason to apply the principle: that when
matters bearing upon the execution, interpretation and validity of the contract are
determined by the law of the place where the contract is made or “lex loci celebrationis”
.
Since the contract was made in the US and US law considers the defendant of legal age,
he has the legal capacity to enter into a contract and therefore making the contract
enforceable against him.