### Facts
1. **Appointment and Service**: Vicente Segovia was appointed Justice of the Peace of Dumanjug, Cebu, on January 21, 1907.
2. **Continuity of Service**: Segovia continuously served in his position until July 1, 1924, when he turned sixty-five.
3. **Order to Vacate**: On July 1, 1924, the Secretary of Justice ordered Segovia to vacate the office in accordance with Act No. 3107, specifying an age limit of sixty-five years for Justices of the Peace.
4. **Assumption of Duties**: Pedro Noel, the auxiliary Justice of the Peace, began to act as Justice of the Peace from July 1, 1924.
5. **Legal Action**: Segovia filed quo warranto proceedings in the Court of First Instance of Cebu, challenging Noel’s right to the office and seeking reinstatement.
6. **Demurrer**: Noel filed a demurrer, arguing the sufficiency of the complaint, citing Act No. 3107’s constitutionality and Segovia’s automatic cessation as Justice upon reaching sixty-five.
7. **Lower Court Ruling**: Judge Adolph Wislizenus of the Court of First Instance ruled in favor of Segovia, overruling the demurrer.
### Issues
1. **Constitutionality**: Whether section 1 of Act No. 3107 is unconstitutional as it impairs Segovia’s contractual right to his office.
2. **Retrospective Application**: Whether the age limitation provision in Act No. 3107 should apply retroactively to Justices of the Peace appointed before the law was enacted.
### Court’s Decision
1. **Public Office as Property**: The Court dismissed Segovia’s claim that section 1 of Act No. 3107 was unconstitutional due to impairment of contractual rights, reiterating that a public office is not considered property nor governed by contractual rights.
2. **Prospective vs. Retrospective Application**: The Court found Act No. 3107 should be applied prospectively, not retroactively. They leaned on a general rule that statutes are presumed to operate prospectively unless explicitly stated otherwise. The Court observed that the provision in question did not indicate retroactive application.
**Resolution of Issues**:
– **Unconstitutionality Claim**: Segovia’s argument regarding the impairment of contractual rights was invalid as a public office is not seen as privately owned or subject to contract principles.
– **Retrospective Application**: Act No. 3107 lacked language suggesting retroactivity; hence, the Court applied it prospectively. Since Segovia’s appointment and service predated the Act, he was not bound by the sixty-five-year age restriction.
### Doctrine
**Prospective Application of Statutes**: A statute is presumed to operate prospectively unless there is a clear legislative intent for retrospective application. This is rooted in a principle of non-interference with existing rights unless explicitly stated by the legislature.
### Class Notes
– **Public Office and Property Rights**: A public office is not equivalent to private property and does not create contractual obligations for the state towards the office-holder.
– **Prospective Application of Laws**: Statutes generally operate prospectively, impacting only future cases unless explicit statutory language mandates retroactive application.
– **Statutory Construction**: Language clarity in statutes is essential. Ambiguities generally favor prospective interpretation to avoid compromising existing rights.
### Historical Background
The issue emerged during a period of American colonial governance in the Philippines, with evolving legislative frameworks seeking to standardize judicial and administrative functions. The case examined the transitional dynamics between existing and new legal prescriptions, emphasizing statutory interpretation principles within a colonial legal context.
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