- Petitioner
- The Treasurer of the Philippine Islands
- Respondent
- Simplicio Rodis
- Citation
- G.R. No. 13012
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Johnson, J.
- Decided
- March 10, 1920
Summary
The Treasurer of the Philippine Islands sued Simplicio Rodis to forfeit his P10,000 security deposit for failing to construct a street railway within the franchise period under Act No. 2034. Despite Rodis's good faith efforts including conducting surveys, preparing plans, and spending P10,000 in preparation, World War I prevented completion. The lower court ordered full forfeiture. The Supreme Court applied Article 1154 of the Civil Code, recognizing Rodis's partial performance in good faith and extraordinary wartime circumstances. Finding no damages to the government, the Court equitably reduced the penalty to P1,000, ordering return of the P9,000 balance. This case demonstrates judicial application of equity principles in contractual penalty mitigation under exceptional circumstances.