G.R. No. L-10154, December 10, 1915
MANUEL GUAZO, plaintiff-appellee, vs. ANA M. RAMIREZ, administratrix of the estate of the late Samuel Bischoff, defendant-appellant.

FACTS:
Manuel Guazo was the manager of sugar haciendas owned by Samuel Bischoff from part of 1910 until September 30, 1912. His compensation consisted of a monthly salary of P100 and a bonus based on the sugar harvest, calculated at 20 centavos per picul if the harvest reached at least 8,000 piculs, with a graduated scale for lesser yields. After Bischoff’s death on June 29, 1913, his wife, Ana M. Ramirez, was appointed administratrix of his estate. Guazo filed a claim for P2,895.20 for unpaid salary and bonus with the committee on claims, which was disallowed. Guazo appealed to the Court of First Instance of Iloilo. Ramirez, as defendant, denied the claim and filed a counterclaim for P30,000, alleging mismanagement, misappropriation, and various other debts. The trial court allowed Guazo’s claim in the reduced amount of P2,205.63, disallowing most of the counterclaim. Ramirez appealed.

ISSUE:
1. Whether the trial court erred in its computation of the amount due to Guazo for his salary and bonus.
2. Whether the trial court erred in disallowing the various items of the defendant’s counterclaim, particularly in allowing Guazo to amend his reply to plead the statute of limitations against old debts.

RULING:
The Supreme Court AFFIRMED the trial court’s judgment.

1. On Guazo’s Claim: The Court found the trial court’s computation of the amount due to be correct. The defendant’s counsel admitted a balance of P2,178.74 was due for salary and bonus, which was close to the P2,205.63 awarded. The Court upheld the trial court’s adjustment of the 1912 bonus claim, reducing it from P1,500 to P881.25 based on evidence showing the harvest was only 8,812.50 piculs, not 15,000 as Guazo estimated. For the 1911 crop, the Court affirmed the award of 20 centavos per picul on 9,834 piculs as stipulated in the contract.

2. On the Counterclaim: The Supreme Court sustained the trial court’s disallowance of the counterclaim items.
The Court agreed that the bulk of the counterclaim, including a P3,000 item, was without merit, noting the complete absence of any prior claim by Bischoff himself for such a large balance.
Regarding old vales and chits from 1896-1898, the Court held the trial court properly allowed Guazo to amend his reply to plead the statute of limitations. The dates of these old claims were not initially disclosed in the pleadings, and Guazo had no knowledge they were time-barred until they were offered in evidence. The Court ruled that the discretion to allow amendments under the Code of Civil Procedure should be exercised to serve justice, and a party must be allowed to plead the statute promptly upon discovering the barred nature of a claim.
* The Court deferred to the trial court’s meticulous, fact-intensive review of the remaining counterclaim items (alleged mismanagement losses, improper charges, etc.), finding no justification in the record to overturn its well-supported conclusions.

The decision was affirmed with costs against the appellant.