Facts:

This case, Pedro Aldaz vs. Vicente Gay, was decided by the Supreme Court of the Philippines on January 2, 1907. The action was initiated in the Court of First Instance of Iloilo, where Aldaz, the plaintiff and appellee, sought damages from Vicente Gay, the defendant and appellant, for alleged breach of contract. The pertinent contract entered into on November 7, 1903, specified that Aldaz would manage Gay's hacienda, named "Fortuna," under several stipulated conditions. These included Gay providing housing and food until June 30, 1904; paying Aldaz a monthly salary of 100 pesos; compensating him 10 centimos for each pico of sugar produced under his management during the 1904-5 crop year; and supplying all necessary resources for the hacienda's cultivation. Aldaz commenced his duties on November 11, 1903, but was discharged on September 20, 1904. Aldaz claimed wrongful termination and sought compensation for the unpaid salary for the remainder

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Facts:

Background of the Case

• The dispute arose from a contract entered into on or about November 7, 1903, between Pedro Aldaz (plaintiff/appellee) and Vicente Gay (defendant/appellant).
• The contract involved the plaintiff managing the defendant’s hacienda known as "Fortuna" under specific conditions.

Terms of the Contract

• The defendant was required to:
• Provide the plaintiff with his house and rations from the time of the contract until June 30, 1904.
• Pay the plaintiff a monthly salary of 100 pesos.
• Pay the plaintiff ten centimos for every pico of sugar produced on the hacienda during the 1904-1905 season.
• Furnish all things necessary for the proper cultivation of the hacienda.
• The plaintiff commenced work on November 11, 1903.

Performance and Discharge

• The plaintiff diligently performed his duties under the contract until September 20, 1904.
• On September 20, 1904, the defendant discharged the plaintiff from his employment.
• The plaintiff contended that his discharge was wrongful, claiming entitlement to:
• The salary for the remainder of the contractual period necessary to complete crop cultivation and harvest for 1904-1905.
• A reasonable amount for his maintenance during the said period.
• Payment of ten centimos per pico for the sugar produced in 1904-1905.

Claims and Counterclaims

• The plaintiff’s claim:
• He was wrongfully discharged.
• He was entitled to recover the unpaid salary for the remaining period of the contract and additional maintenance wages for said period.
• He was also entitled to the agreed amount per pico on the sugar produced in the harvest season.
• The defendant’s claim:
• The discharge was justified due to noncompliance with the contract.
• Accordingly, the plaintiff was not entitled to the remaining salary or the pico-based payment.

Findings of the Lower Court

• Breach and Damage:
• The court found that the plaintiff was wrongfully discharged.
• The plaintiff was thus entitled to a monthly salary at the rate of 100 pesos for five months—the estimated period necessary to complete cultivation and harvesting of the crop for 1904-1905—totaling 500 pesos.
• Sugar Crop Yield Evidence:
• Conflicting testimonies existed regarding the number of sugar picos:
• Plaintiff’s witnesses estimated between 14,000 to 20,000 picos.

ii. Defendant’s witnesses estimated between 8,000 to 14,000 picos.

Reference to Prevailing Jurisprudence

• The court cited established American jurisprudence on wrongful discharge, highlighting that:
• An employee wrongfully discharged is entitled to recover wages up to the termination of the contractual period (prima facie damage).
• The burden is on the employer to prove that the discharged employee sought or could have secured alternative employment.
• The case referenced similar principles from cases such as Howard vs. Daly, Allen vs. Whitlark, and Farrell vs. School District No. 2.

Issue:

Whether the plaintiff was wrongfully discharged from his employment under the terms of the contract.

• Examination of the contractual provisions regarding termination and maintenance benefits.
• Determination of whether the discharge constituted a breach of the contractual obligations by the defendant.

Whether the plaintiff was entitled to recover:

• Salary for the remaining period necessary to complete the cultivation and harvesting of the crop for the year 1904-1905.
• Additional maintenance wages for the period covered by the contract (noting the limitation beyond June 30, 1904, as per the contract terms).
• Payment at the rate of ten centimos per pico for the sugar produced, specifically for the portion of the crop where his labor was performed.

• Whether the evidence regarding the actual number of sugar picos produced can justify the award calculated on one-half of the estimated yield.

• Whether the plaintiff’s failure to seek alternative employment affects his right to recover damages under the wrongful discharge.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)