Title
Arroyo vs. Hospital de San Pablo
Case
G.R. No. L-659
Decision Date
Jul 28, 1948
Plaintiff claimed unpaid P600 monthly salary as hospital director from 1911-1945; court dismissed due to lack of evidence, gratuitous service confirmation, and inconsistent conduct.
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Case Digest (G.R. No. L-659)

Facts:

Appointment and Initial Agreement

  • Plaintiff Mariano B. Arroyo was appointed as the director of Hospital de San Pablo in May 1911, allegedly at a monthly salary of P600. He claims to have received an advance payment of P3,600 for six months.
  • Defendant (Hospital de San Pablo) admits that Arroyo served as director from May 1911 to May 1945 but disputes the salary claim. They assert that Arroyo was paid P50 monthly from May 1914 to August 1916 and thereafter served voluntarily without compensation.

Dispute Over Salary

  • Plaintiff alleges that from November 1916, the hospital stopped paying his salary, and he continued to serve until May 1945 without receiving further payments.
  • Defendant counters that Arroyo voluntarily served without salary after August 1916, citing a written confirmation from Arroyo dated March 20, 1923, where he ratified his gratuitous service.

Evidence Presented

  • Plaintiff presented witnesses, including himself, to support his claim of a P600 monthly salary. He also testified about a 1923 agreement with the Mother Superior, Sor Adriana, to deposit his salary with the hospital, which was never paid.
  • Defendant presented witnesses, including Sor Antonia Guedo, who testified that Arroyo never received a P600 salary and had agreed to serve gratuitously. They also presented a cash book showing payments of P50 monthly to Arroyo until 1918.

Plaintiff’s Conduct

  • Plaintiff admitted to performing surgeries while intoxicated and claimed he did not demand payment for his services for decades due to his position as director.
  • Defendant argued that Arroyo’s conduct, including his failure to demand payment for nearly 30 years, was inconsistent with his claim of a P600 monthly salary.

Other Testimonies

  • Witnesses for the defendant testified that Arroyo often bragged about his lucrative private practice and stated he served the hospital without salary to support its charity ward.
  • Plaintiff’s testimony in a 1932 case (Exhibits X-1 and X-2) contradicted his current claim, as he had previously stated under oath that he received no salary from the hospital.

Issue:

  1. Whether there was a valid agreement for a P600 monthly salary between Arroyo and the Hospital de San Pablo.
  2. Whether Arroyo voluntarily served as director without compensation after 1916.
  3. Whether Arroyo’s claim for unpaid salaries is barred by laches or prescription.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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