Title
Arroyo vs. Azur
Case
C.A. No. 9320
Decision Date
Apr 13, 1946
Timoteo Arroyo, a domestic servant, claimed unpaid wages for 12 years of service under a verbal agreement. The Supreme Court ruled in his favor, stating the Statute of Frauds doesn’t apply to executed contracts, awarding P1,440 plus interest.
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Case Digest (C.A. No. 9320)

Facts:

  1. Parties Involved:

    • Claimant/Appellant: Timoteo Arroyo, a domestic servant who served Eleuterio Dura and his wife, Andrea Azur, for 12 years (1921–1932).
    • Oppositors/Appellees: Andrea Azur (widow and administrator of Eleuterio Dura’s estate) and collateral relatives of Eleuterio Dura.
  2. Nature of the Claim:

    • Timoteo Arroyo claimed compensation for 12 years of domestic and agricultural services rendered to Eleuterio Dura and Andrea Azur.
    • The verbal agreement was for a monthly wage of P10, with the understanding that payment could be made in cash or in kind (e.g., a piece of land).
    • No payment was made during Eleuterio Dura’s lifetime.
  3. Proceedings:

    • After Eleuterio Dura’s death in 1932, Andrea Azur was appointed administrator of his estate.
    • Timoteo Arroyo filed his claim before the Commission on Appraisal and Claims, which awarded him P1,200 in 1939.
    • The collateral heirs opposed the award and appealed to the Court of First Instance of Camarines Sur.
    • The Court of First Instance dismissed the claim, ruling that the verbal contract was unenforceable under the Statute of Frauds (Article 335 of the Civil Code and Article 21, Rule 123 of the Rules of Court).
  4. Appeal:

    • Timoteo Arroyo appealed the dismissal, arguing that the Statute of Frauds did not apply to his claim.

Issue:

  1. Primary Issue:

    • Whether the Court of First Instance erred in dismissing Timoteo Arroyo’s claim solely because the verbal contract for services was not in writing.
  2. Secondary Issues:

    • Whether the Statute of Frauds applies to contracts that have been partially or fully executed.
    • Whether the oppositors should be allowed to present evidence after their motion to dismiss was denied on appeal.
    • Whether the claim was barred by prescription or filed out of time.

Ruling:

  1. On the Statute of Frauds:

    • The Supreme Court ruled that the Statute of Frauds does not apply to contracts that have been partially or fully executed. Since Timoteo Arroyo had already rendered his services, the contract was executed, and the Statute of Frauds was inapplicable.
  2. On the Motion to Dismiss and Reservation of Evidence:

    • The Court held that the oppositors, by filing a motion to dismiss without presenting evidence, waived their right to present evidence later. The case should be decided on the merits based on the evidence already on record.
  3. On the Merits of the Claim:

    • The Court found sufficient evidence to support Timoteo Arroyo’s claim, including his testimony and that of Andrea Azur, who confirmed the terms of the verbal agreement.
    • The Court awarded Timoteo Arroyo P1,440 (P10/month for 12 years) plus legal interest from the filing of the claim.
  4. On Prescription:

    • The Court rejected the oppositors’ argument that the claim was filed out of time, as the demand was filed within the period set by the Court of First Instance.

Ratio:

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