INSULAR GOVERNMENT vs.

FRANK
FACTS: In 1903, in the city of Chicago, Illinois, Frank entered into a contract for a
period of 2 years with the Plaintiff, by which Frank was to receive a salary as a
stenographer in the service of the said Plaintiff, and in addition thereto was to be paid in
advance the expenses incurred in traveling from the said city of Chicago to Manila, and
one-half salary during said period of travel.Said contract contained a provision that in
case of a violation of its terms on the part of Frank, he should become liable to the
Plaintiff for the amount expended by the Government by way of expenses incurred in
traveling from Chicago to Manila and the one-half salary paid during such period. Frank
entered upon the performance of his contract and was paid half-salary from the date
until the date of his arrival in the Philippine Islands. The Plaintiff commenced an action
in the CFI-Manila to recover from Frank the sum of money, which amount the Plaintiff
claimed had been paid to Frank as expenses incurred in traveling from Chicago to
Manila, and as half-salary for the period consumed in travel.
ISSUE: Did the amendment of the laws altered the tenor of the contract entered into
between Plaintiff and Defendant?
HELD: the judgment of the lower court is affirmed. NO; It may be said that the mere fact
that the legislative department of the Government of the Philippine Islands had
amended said Acts No. 80 and No. 224 by Acts No. 643 and No. 1040 did not have the
effect of changing the terms of the contract made between the Plaintiff and the
Defendant. The legislative department of the Government is expressly prohibited by
section 5 of the Act of Congress of 1902 from altering or changing the terms of a
contract. The right which the Defendant had acquired by virtue of Acts No. 80 and No.
224 had not been changed in any respect by the fact that said laws had been amended.
These acts, constituting the terms of the contract, still constituted a part of said contract
and were enforceable in favor of the Defendant.
 NORSE MANAGEMENT VS. NATIONAL SEAMEN
FACTS: Napoleon B. Abordo, the deceased husband of private respondent Restituta C.
Abordo, was the Second Engineer of M.T. "Cherry Earl" when he died from an
apoplectic stroke in the course of his employment with petitioner NORSE
MANAGEMENT COMPANY (PTE). The M.T. "Cherry Earl" is a vessel of Singaporean
Registry. In her complaint for compensation benefits filed before the National Seamen
Board, private respondent alleged that the amount of compensation due her from
petitioners should be based on the law where the vessel is registered. Petitioners
contend that the law of Singapore should not be applied in this case because the
National Seamen Board cannot take judicial notice of the Workmen's Insurance Law of
Singapore instead must be based on Board’s Memeorandum Circular No. 25. Ministry
of Labor and Employment ordered the petitioner to pay jointly and severally the private
respondent. Petitioner appealed to the Ministry of Labor but same decision. Hence, this
petition.
ISSUE: Whether or not the law of Singapore ought to be applied in this case.
HELD: The SC denied the petition. It has always been the policy of this Board, as
enunciated in a long line of cases, that in cases of valid claims for benefits on account
of injury or death while in the course of employment, the law of the country in which the
vessel is registered shall be considered. In Section 5(B) of the Employment Agreement
between petitioner and respondent’s husband states that In the event of illness or injury
to Employee arising out of and in the course of his employment and not due to his own
willful misconduct, EMPLOYER will provide employee with free medical attention. If
such illness or injury incapacitates the EMPLOYEE to the extent the EMPLOYEE's
services must be terminated as determined by a qualified physician designated by the
EMPLOYER and provided such illness or injury was not due in part or whole to his
willful act, neglect or misconduct compensation shall be paid to employee in accordance
with and subject to the limitations of the Workmen's Compensation Act of the Republic
of the Philippines or the Workmen's Insurance Law of registry of the vessel whichever is
greater. Finally, Article IV of the Labor Code provides that "all doubts in the
implementation and interpretation of the provisions of this code, including its
implementing rules and resolved in favor of labor.