Case Summary (A.M. No. CA-13-51-J)
Employment and Salary Increases
Mercader's employment commenced on May 11, 1946, at a monthly salary of ₱375. This amount was later increased to ₱400 on August 19, 1949, which included ₱375 as regular pay and an additional ₱25 for work performed on Sundays, legal holidays, overtime, and special duties. Moreover, he was entitled to two weeks of paid vacation leave each year and 12 days of paid sick leave for proven illness.
Separation from Employment
On March 26, 1951, Mercader sought leave from April 1 to August 1, 1951, which was granted. However, during this leave, he received a letter dated April 17, 1951, from the Club manager, which imposed a limit of two weeks' sick leave for 1951 and included a severance pay of one month’s salary. Discontented with his separation, Mercader subsequently filed a claim with the Department of Labor for ₱10,000 regarding overtime and other privileges on June 16, 1951.
Labor Secretary’s Ruling and Settlement
The Department of Labor, after due proceedings, ordered the Manila Polo Club to pay Mercader ₱10,623.24 on September 24, 1951. However, an amicable settlement occurred on November 9, 1951, wherein Mercader received ₱7,000 in full settlement for any claims against the Club, which included claims for overtime work, vacation, and sick leave.
Subsequent Legal Action
Despite the settlement, Mercader filed a complaint with the Court of First Instance in Manila on January 9, 1953. He claimed that his employment had been wrongfully terminated, seeking compensatory damages, moral damages, and attorney’s fees. The Manila Polo Club acknowledged his employment but contended his separation was justified due to his poor work performance. The Club asserted that the matter was settled with the ₱7,000 payment.
Court’s Decision
The trial court dismissed Mercader's complaint, finding that the evidence favored the defendants and that Mercader had waived his claims through the prior settlement agreement. The court determined that regardless of the employment's nature, Mercader had no grounds for action against the Club due to the waiver. The court also found that Alex D. Stewart, acting as an agent for the Club, could not be held liable for Mercader’s separation.
Appellate Review
On appeal, Mercader assigned errors to the tr
...continue readingCase Syllabus (A.M. No. CA-13-51-J)
Case Overview
- The case revolves around Alejandro Mercader (plaintiff and appellant) and the Manila Polo Club along with Alex D. Stewart (defendants and appellees).
- The core issue is the termination of Mercader's employment and the subsequent claims for unpaid overtime, vacation, and sick leave.
Employment History
- Alejandro Mercader was employed by the Manila Polo Club on May 11, 1946, as a bookkeeper and accountant with a starting salary of P375 per month.
- On August 19, 1949, his salary increased to P400, which included a P25 premium for work on Sundays, holidays, and overtime.
- Mercader was entitled to two weeks of paid vacation and 12 days of paid sick leave each year.
Request for Leave and Termination Notice
- Mercader requested leave from April 1 to August 1, 1951, which was granted.
- While on leave, he received a letter from H.J. MacLean, the Club's manager, stating that the Club would only allow two weeks of sick leave for the year and included a severance pay check for P405.
Filing a Claim
- Discontent with the separation from the Club, Mercader filed a claim with the Department of Labor on June 16, 1951, for P10,000, citing unpaid overtime and other benefits.
- On September 24, 1951, the Secretary of Labor ordered the Manila Polo Club to pay Mercader P10,623.24.
Settlement Agreement
- On November 9, 1951, Mercader and his attorney entered into an amicable s