What is the proper measure of compensation for unpaid labour in a constructive trust situation?

In McLean v. Danicic, [2009] O.J. No. 2356 (S.C.J.), at pars. 68-72, the court discussed whether the proper measure of a monetary award in a constructive trust situation is only the value of services provided at the time, the “value received” approach, or the “value surviving” approach, which would look at a portion of the value of the assets of the couple at the separation. In that case the services provided were largely in the form of unpaid labour contributed toward clearing land, building a cottage, renovating another property, domestic household work and assisting in the respondent’s business. The applicant added up her hours and submitted a claim for 9,515 hours over five years, for which the court awarded compensation at the minimum wage rate because that was a rate of which the court could take judicial notice. Fortunately for the applicant (and the trial judge), McLean v. Danicic was an uncontested trial and so the hours claimed and the rate of notional pay were not subject to controversy.