G.R. No. 2826

FACTS:
1. Parties:
– Plaintiff-Appellee: Pedro Aldaz
– Defendant-Appellant: Vicente Gay

2. Contract Terms (November 7, 1903):
– Aldaz was to manage Gay’s hacienda “Fortuna” under specified conditions:
– Gay would provide housing and rations until June 30, 1904.
– Gay would pay Aldaz a monthly salary of 100 pesos.
– Gay would pay Aldaz 10 centimos per pico of sugar produced in 19041905.
– Gay would furnish necessary resources for cultivation.

3. Breach and Dispute:
– Aldaz worked from November 11, 1903, until his discharge on September 20, 1904.
– Aldaz claimed wrongful termination, seeking unpaid salary for the remaining contract period (estimated at 5 months) and 10 centimos per pico of sugar produced in 19041905.
– Gay argued the discharge was justified due to Aldaz’s noncompliance with the contract.

4. Lower Court Ruling:
– Found Aldaz was wrongfully discharged.
– Awarded Aldaz:
– 500 pesos (5 months’ salary at 100 pesos/month).
– 700 pesos (10 centimos/pico for half of the estimated 14,000 picos of sugar, acknowledging Aldaz’s partial performance).
– Denied maintenance claims post-June 30, 1904, as the contract excluded this obligation.

ISSUE:
1. Whether Aldaz was wrongfully discharged, entitling him to damages for breach of contract.
2. Whether Aldaz failed to mitigate damages by not seeking alternative employment post-discharge.

RULING:
1. Wrongful Discharge:
– The Supreme Court affirmed the lower court’s finding that Aldaz was wrongfully terminated, justifying damages for lost salary (500 pesos).

2. Mitigation of Damages:
– The burden to prove Aldaz could have found similar employment (thus reducing damages) lay with Gay, who presented no such evidence.
– Citing Howard v. Daly, the Court held that Aldaz’s prima facie damages were his stipulated compensation unless Gay proved mitigation opportunities.

3. Sugar Production Compensation:
– The award of 700 pesos (for half the estimated 14,000 picos) was upheld, as Aldaz had substantially performed half the work.

4. Maintenance Claim:
– Correctly denied, as the contract limited this obligation to June 30, 1904.

Disposition:
– Judgment affirmed with costs against Gay.
– Case remanded to the lower court for execution.

Concurring Justices:
Arellano, C.J., Torres, Mapa, Carson, Willard, and Tracey, JJ.

(Note: The ruling emphasizes employer liability for wrongful termination and the defendant’s burden to prove mitigation of damages under contract law principles.)