Case Digest (G.R. No. 135382) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Anselmo Ferrazzini was engaged by Carlos Gsell under an indefinite employment in Manila for his “skilled service” at a fixed monthly salary, with a contractual clause requiring six months’ written notice before discharge. In 1916, Ferrazzini sued Gsell for damages on the ground of a wrongful discharge, alleging no just cause had been shown and the six‐month notice not given. Gsell admitted noncompliance with the notice clause but asserted that Ferrazzini’s repeated absences from the factory to drink during working hours, his unfaithfulness in inducing other employees to distrust management, and his disobedience of orders justified dismissal. Gsell also counterclaimed for liquidated damages under a post‐employment non-competition clause forbidding Ferrazzini, for five years after termination, from engaging in any enterprise in the Philippines without written consent, stipulating ₱10,000 per breach. The trial court ruled for Ferrazzini, Case Digest (G.R. No. 135382) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Nature of the Contract
- Anselmo Ferrazzini (“plaintiff”) was employed by Carlos Gsell (“defendant”) for an indefinite term at a fixed monthly salary to render skilled services exclusively in the defendant’s industrial enterprises in Manila.
- The written contract required the master to provide six months’ written notice before discharge, and obliged the servant to devote full time, loyalty, discretion, and obedience to reasonable orders.
- Circumstances Leading to Discharge
- Defendant discharged plaintiff without six months’ notice, alleging just cause based on:
- Plaintiff’s habit of leaving the factory during work hours to take alcoholic drinks, despite being ordered to stop.
- Plaintiff’s remarks at a communal mess accusing the defendant of lacking confidence in his employees and disparaging a fellow foreman’s salary.
- Plaintiff claimed informal permission to take brief drink breaks; defendant and factory manager Bender testified that such permission had been revoked and orders were repeatedly disobeyed.
- Trial Court Proceedings and Counterclaim
- Trial court found the discharge unjustified, awarded damages to plaintiff, and refused to consider defendant’s counterclaim.
- Defendant had amended his answer at trial to allege plaintiff breached a post‐employment non‐compete clause by entering the service of another Philippine employer without written consent, seeking P10,000 liquidated damages. Trial court disregarded the counterclaim on procedural grounds.
Issues:
- Was the plaintiff’s discharge justified under the express and implied terms of the employment contract?
- Was the defendant’s counterclaim based on the post‐employment restraint clause properly received and enforceable?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)