Thursday, July 6, 2023

Case Digest: Lirag Textile, Inc. et.al. vs CA et.al., G.R. No. L-30736

Lirag Textile, Inc. and Felix K. Lirag vs Court of Appeals and Cristan Alcantara, GR No. L-30736, July 11, 1975

Subject: Obligations and Contracts

FACTS

There is an express agreement between petitioner Lirag Textile Mills, Inc. and private respondent Cristan Alcantara as to the period of the latter's employment in the former's firm, that definite period starting from Alcantara's employment up to the time Alcantara may voluntarily resign or when petitioner Lirag Textile Mills may remove Alcantara for a valid cause or causes.

Lirag Textile Mills, Inc. terminated Alcantara without valid cause.

ISSUE

Whether or not Lirag Textile, Inc. committed a breach of contract which made it liable to Alcantara for damages.

RULING

Yes, Lirag Textile, Inc. committed a breach of contract which made it liable to Alcantara for damages

Under the law (Art 1193), obligations for whose fulfillment a day certain has been fixed, shall be demandable only when that day comes. Obligations with a resolutory period take effect at once, but terminate upon arrival of the day certain. A day certain is understood to be that which must necessarily come, although it may not be known when. If the uncertainty consists in whether the day will come or not, the obligation is conditional, and it shall be regulated by the rules of Art 1192.

In this case, Lirag Textile Mills, Inc. thereby committed a breach of contract which made it liable to Alcantara for damages. In an action by Alcantara for damages, RA 1052 as amended (the Termination Pay Law when there is no time fixed for employment) will not apply because there is an express agreement as to the period of Alcantara’s employment which is up to the time Alcantara may voluntarily resign, or when the employer removes Alcantary for a valid cause. Thus, the employment has a period subject only to the resolutory condition of resignation or removal for cause. The findings of the court states otherwise, the employer terminated Alcantara’s employment without valid cause hence valid ground for breach of contract making it liable for damages.

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