Case Digest (G.R. No. 5671) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On January 22, 1905, Veronica Alojado borrowed ₱67.60 from Benito de los Reyes to settle a debt owed to Olimpia Zaballa. They agreed that Alojado would work as a domestic servant in Reyes’s household without remuneration until she secured funds to repay the loan. On March 12, 1906, she left Reyes’s service without making any payment despite his repeated demands. Reyes filed suit on March 15, 1906, before the Justice of the Peace of Santa Rosa, La Laguna, seeking either the ₱67.60 or enforcement of the service agreement. On April 14, 1906, the justice of the peace ordered Alojado to pay the loan or, if insolvent, remain in service as agreed, and assessed costs against her. Alojado appealed to the Court of First Instance, and Reyes moved to disallow the appeal for late filing, but this was denied on July 16, 1906, when the court found that notice of judgment was served on April 16 and the appeal was timely filed on April 20. Reyes then reproduced his complaint on May 4, 1906, amen Case Digest (G.R. No. 5671) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Loan and Agreement
- On January 22, 1905, Benito de los Reyes lent P67.60 to Veronica Alojado to enable her to pay a debt owed to Olimpia Zaballa.
- It was agreed that Alojado would remain as a domestic servant in Reyes’s household without any remuneration until she could find funds to repay the loan.
- Breach and Initial Suit
- Veronica Alojado left Reyes’s service on March 12, 1906, without repaying the loan despite repeated demands.
- On March 15, 1906, Reyes filed suit before the Justice of the Peace of Santa Rosa, La Laguna, seeking payment of P67.60 or, alternatively, enforcement of the service agreement.
- Justice of the Peace Proceedings
- On April 14, 1906, judgment was rendered ordering Alojado to pay the loan; if insolvent, she was to resume service without remuneration. Costs were assessed against her.
- Alojado appealed to the Court of First Instance of La Laguna.
- Procedure in the Court of First Instance
- Reyes moved to disallow the appeal for lateness under section 76 of the Code of Civil Procedure; this was denied because Alojado was not notified until April 16, and her appeal was filed April 20 (within five days).
- On May 4, 1906, Reyes was instructed to reproduce his complaint; he added allegations that Alojado had also received P11.97 in small advances during her service.
- Pleadings and Trial
- In her answer of August 15, 1906, Alojado denied owing the sums and counterclaimed for unpaid wages and undelivered effects.
- Trial was held October 19, 1906; on November 21, 1906, the court absolved Alojado, found she was owed P82 in wages, netting P2.43 in her favor, and assessed costs against Reyes.
- Appeal to the Supreme Court
- Reyes filed exceptions to the CFI judgment, moved for new trial on ground that findings were contrary to the weight of evidence; motion denied December 17, 1906.
- Bill of exceptions was duly forwarded, presenting the issue of the legality of the gratuitous service condition.
Issues:
- Whether a contract by which a domestic servant agrees to render gratuitous service in satisfaction of a debt is valid under Philippine law.
- Whether the trial court correctly balanced the sums loaned (P79.57) against the wages due (P82) to arrive at a net award of P2.43 in favor of the defendant.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)