G.R. No. L-2779 - Sanchez vs. Harry Lyons Construction, Inc.

The case originated in the Municipal Court of Manila upon a complaint filed on March 9, 1948, by the appellees (plaintiffs) against the appellants (defendants) for P2,210 plus interest, which represented one month advance pay due.
On April 28, 1948, the parties entered into a stipulation of facts upon which the Municipal Court rendered judgment for the plaintiffs.
After the defendants’ motion for reconsideration was denied, they appealed to the Court of First Instance of Manila, where the case was submitted on the same agreed facts.
On October 2, 1948, the Court of First Instance rendered its decision ordering payment of specific sums to individual plaintiffs and apportioned costs between the defendants.

Enrique Ramirez and Juan Ramirez were employed as warehouseman with salaries of P450 (later reduced to P360) and P250 a month, respectively, by Defendant Harry Lyons Construction, Inc.
Daniel Sanchez, employed as a carpenter-foreman at P250 a month, and several others employed on a daily basis as guards for P5 per day, were also engaged under contracts of employment.

Employment could be terminated at any time without previous notice.
Salary or wages would be computed and paid only up to the date of termination.
The employees expressly waived the benefit of Article 302 of the Code of Commerce and similar provisions requiring notice or subsequent pay upon discharge.

The plaintiffs were dismissed on December 31, 1947, without the requisite one-month notice.
Each plaintiff demanded the payment equivalent to one month’s salary, which the defendants refused to pay, prompting the filing of the complaint.

The key dispute centers on whether the plaintiffs, regardless of being paid on a monthly or daily basis, are entitled to the benefits under Article 302 of the Code of Commerce—that is, the one-month notice pay (mesada).
The secondary issue is the legality and validity of the plaintiffs’ preemptive waiver of these benefits in their employment contracts.

Whether the plaintiffs, employed as warehousemen, a carpenter-foreman, and guards—and being paid either monthly or daily—are entitled to the benefits provided by Article 302 of the Code of Commerce.
Whether the waiver of the one-month notice pay (mesada) contained in the contracts of employment, executed in advance by the plaintiffs, is legally valid or void as contrary to public policy.