G.R. No. L-14947 - Mirano vs. Madrigal and Co., Inc.

Plaintiffs consist of 25 seamen employed as crew members of three vessels – SS Argus, SS Churruca, and SS Hirondelle – owned by defendant Madrigal & Company, Inc.
The employment was based on individual contracts known as “shipping articles,” which were executed by each seaman prior to departure.
The vessels were contracted for a voyage from Manila to Hongkong for the purpose of dry-docking and repairs.

On November 2, 1941, the plaintiffs departed the Philippines aboard the defendant’s vessels, arriving in Hongkong on November 5, 1941.
The “shipping articles” served as the binding employment contracts outlining the terms and conditions agreed between each seaman and the defendant.
The contracts were not produced at trial because, according to the plaintiffs, they were destroyed or lost during the war.

War erupted between the United States and Japan on December 8, 1941, altering the course of the plaintiffs’ employment.
On December 15, 1941, the plaintiffs were captured by the Imperial Japanese Army and subsequently detained and forced to serve as slave labor aboard several vessels, including the “SS Saiyong.”
The imprisonment involved transfers including an interment in Macao, towing to Hongkong, and eventual transport of the seamen back to the Philippines.
The period of forced service and captivity extended until September 21, 1944, when some seamen managed to escape following the American bombing of Manila.

The plaintiffs claimed non-payment of wages for the period from November 2, 1941, to September 21, 1944, with individual amounts ranging from less than P2,000 to over P15,000.
The aggregate claim for wages amounted to P56,561.24, with detailed individual amounts specified for each crew member.
In addition to wage claims, the plaintiffs prayed for P100,000.00 in damages (both material and moral) and for the payment of costs.

Defendant Madrigal & Company, Inc. filed multiple motions to dismiss the complaint on various grounds:

Alleged failure to state sufficient allegations constituting a cause of action.
Lack of jurisdiction over claims where individual demands did not exceed P2,000.00.
Prescription of the action.

The lower court denied the initial motion to dismiss and later, following several pleadings and a trial with testimonial and documentary evidence, rendered a judgment on jurisdiction.
The trial court, based on evidence that each seaman individually signed a “shipping article,” held that each claim is an independent cause of action and thus must meet the jurisdictional threshold individually rather than in aggregate.

After the trial court’s sweeping dismissal based on jurisdictional grounds, the case was divided for separate considerations:

Dismissal for the majority of plaintiffs whose individual claims were less than the statutory threshold.
Exception made for plaintiff Mauricio Mirano, whose claim as Chief Engineer was P15,615.00, exceeding the minimum requirement.

Whether the defendant truly employed them as crew.
The waiver or estoppel of the defendant’s non-liability defense due to its admissions in previous pleadings.
The impact of war on the defendant’s obligation to pay wages.
The method of computing jurisdiction by aggregating claims versus considering each claim separately.

Whether Madrigal & Company, Inc. was indeed the employer contracting the seamen through individually executed “shipping articles.”
Whether the non-production of the shipping articles due to war circumstances affected the determination of the employment terms.

Whether the defendant waived its defense of non-liability or was estopped from denying liability by its admissions in its motions to dismiss and answer.

Whether the outbreak of war and subsequent conditions (capture, forced labor, and imprisonment) extinguished or modified the defendant’s obligation to pay wages.

Whether the jurisdiction of the court should be determined by the aggregate amount of the plaintiffs’ claims or by each individual claim, particularly when some demands were below the statutory threshold (P2,000.00 or P5,000.00).
Whether each seaman’s individually signed “shipping article” constitutes a separate and independent cause of action that must independently satisfy the jurisdictional requirement.