Robert S. Clemons v. William T. Nolting

Summary

In this mandamus proceeding, American engineer Robert S. Clemons challenged the Government Auditor's refusal to countersign a warrant paying the currency depreciation difference in his salary. Clemons had contracted to receive $4,000 annually in US dollars, but the Government attempted payment in Philippine pesos at the statutory 2:1 rate despite significant peso depreciation. The Supreme Court unanimously ruled that contractual obligations specifying particular currency must be honored according to their terms, not statutory exchange rates. The Court emphasized that Article 1170 of the Civil Code requires payment in stipulated specie, and allowing governments to discharge dollar obligations with depreciated pesos would constitute partial repudiation and harm commercial confidence. The decision established important precedent protecting contractual currency specifications against legislative impairment, particularly relevant during periods of currency instability in the early American colonial period.