GOVT. OF THE PHILIPPINE ISLANDS (GPI) v.

GEORGE FRANK
G.R No. 2935 / 23 March 1909
Johnson
A. Villafuerte
SUMMARY: Matters bearing upon the execution, interpretation and validity of a contract are
determined by the law of the place where the contract is made. Since Frank entered into the
contract in Illinois, his capacity to enter into a contract is determined by the laws of Illinois.
As he has already passed the age of majority in said state, the contract is binding on him,
even though he is still considered a minor under the laws of the place of performance.
FACTS
In Chicago, Illinois, George Frank entered into a two-year contract with the GPI whereby he is
to serve as a stenographer ($1,200 annual salary, with travelling expenses from Chicago to
Manila and salary during travel periods). It was also stipulated that in case Frank violates
the contract, he should pay GPI the travelling expenses + the salary received during
travel periods. The parties expressly agreed that Laws No. 80 and 224 should constitute part
of their contract. At the time he entered into said contract in Illinois, he has already
reached the age of majority as provided for under Illinois law. 1
Eventually, Frank left the service of the government and refused to comply with the terms of
the contract. Hence, the government commenced an action to recover from Frank the sum
of $269.23.
Frank argues that at the time he entered into the contract, he was a minor and was
therefore not responsible under the law, and that the government amended the
aforementioned laws, thereby materially altering their contract. The lower court ruled in
favor of the government.
ISSUE & HOLDING
WON Frank can plead minority as a defense at the place where the contract is being
enforced. NO
WON the amendments to the laws affected the terms of the contract. NO
RATIO
Subject Matter
Execution, interpretation and validity of a
contract
Performance of the contract
Remedy (such as bringing of suit,
admissibility of evidence, statutes of
limitations)

Governing law
Law of the place where the contract is
made
Law of the place of performance
Law of the place where the suit is brought

Franks claim that he was an adult when he left Chicago (after signing the contract), but was
a minor when he arrived at Manila more than a year later (and therefore, the contract
cannot be enforced on him), is not tenable. At the time the contract was entered, he
was an adult under the laws of Illinois and had full authority to contract.
The mere fact that the legislative department amended said acts did not have the effect of
changing the terms of the contract herein. The said acts, constituting the terms of the
contract, still constituted a part of said contract and were enforceable in favor of Frank.

1 Note that at that time, the age of majority in the Philippines was 23 years.