G.R. No. and Date: G.R. No. L-11102, January 28, 1918

FACTS:
The plaintiff, H. C. Best, was employed by the defendant partnership, Lizarraga Hermanos, as superintendent of its sugar central “Bearin” in Kabankalan, Occidental Negros, under a contract running from March 1914 until April or May 1915, with a monthly salary of P450 plus board, lodging, and other services. Serious misunderstandings and difficulties arose between Best and his employers, partly due to his lack of experience in dealing with Filipino laborers, his inability to communicate directly with them, and perceived lack of tact, which led to disaffection among the personnel. An incident occurred where laborers stoned Best after an altercation. Following an investigation, the senior member of the firm found the entire personnel disaffected and that retaining Best would likely cause other employees to quit. In a conference, the defendants asked Best to resign and offered to pay his salary in advance, which he refused. The next day, Best left the central and did not return. He subsequently filed an action for damages for breach of contract, claiming he was effectively discharged without justification. The Court of First Instance ruled in favor of Best, awarding him damages. The defendants appealed.

ISSUE:
Whether the plaintiff, H. C. Best, is entitled to recover damages from the defendants for alleged breach of his employment contract.

RULING:
No. The Supreme Court reversed the judgment of the lower court insofar as it awarded damages for the unexpired portion of the contract. The Court found that Best was not discharged but quit his position, forced by conditions for which he was primarily responsible due to his inability to maintain “good service and order” as required by his contract. The conditions that made his continuance impracticable resulted chiefly from his own failure to fulfill his contractual duties. The Court held that where both parties to a contract are at fault, or where the contract becomes impracticable without the fault of either, neither party can maintain an action for breach against the other. The situation was deemed substantially one where the contract was dissolved by mutual consent. However, the plaintiff was entitled to recover the salary earned up to the date of his departure, calculated as P1,771 for four months less two days, minus the P730 he admitted having received, with interest from the date of the complaint’s filing. The offer by the defendants to reinstate Best, though not properly considered by the lower court, was noted as potentially relevant to mitigating damages.

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