GR 4348; (September, 1908) (Digest)
Here’s the digest of the case:
FACTS:
MAURICIA MAJARABAS, ET AL. rendered services as a wet nurse and governess for the infant daughter of INOCENCIO LEONARDO. This was based on a verbal agreement with INOCENCIO LEONARDO‘s now-deceased parents, who promised to “liberally compensate” MAURICIA MAJARABAS by providing for “the maintenance of herself, her husband and their child” for the entire period of her services.
INOCENCIO LEONARDO filed a demurrer, arguing that the obligation was for support (Article 150 of the Civil Code), which was extinguished upon the death of the obligors (his parents), and thus MAURICIA MAJARABAS could not sue for compliance. The lower court overruled the demurrer, holding that the agreement constituted a contract for services, with the price being measured by MAURICIA MAJARABAS‘s maintenance.
INOCENCIO LEONARDO appealed, maintaining that a contract for services requires a “specified price” (Article 1544 of the Civil Code), which he claimed was absent in the verbal agreement. He also disputed the existence of the agreement, the duration of the services, and the P0.50 per day compensation rate determined by the lower court.
ISSUE:
1. Whether the verbal agreement to compensate MAURICIA MAJARABAS through the “maintenance of herself, her husband and their child” constitutes a “specified price” required for a valid contract of lease of services under Article 1544 of the Civil Code.
2. Whether the factual findings of the lower court regarding the existence of the contract, duration of service, and amount of compensation were supported by evidence.
RULING:
1. Yes. The Supreme Court affirmed the lower court’s decision, holding that the agreement contained a “specified price” as required by Article 1544 of the Civil Code. The Court clarified that a “fixed price” does not necessarily mean an actual or determined monetary sum at the time the contract is executed. It is sufficient if the price can be determined through the stipulations of the contract, by referring to a “determinate thing also specific” (by analogy to Article 1447 of the Civil Code concerning contracts of purchase and sale). In this case, the “maintenance of the plaintiff and her family” was the specific and determinate thing that fixed the price, as its cost determined the price according to the agreement. The actual cost of maintenance would be a matter of proof, but the basis for determining the price was specified.
2. Yes. The Supreme Court found that the lower court’s factual findings were supported by the testimony of witnesses. The evidence showed that the agreement was indeed made, that MAURICIA MAJARABAS served from January 1901 to the end of June 1903 (two and a half years), and that the compensation of P0.50 per day (P15 per month), representing the cost of her maintenance, was proven and reasonable.
The Supreme Court affirmed the judgment appealed from, with costs against the appellant.
