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Prof. Joselito Guianan Chan's The Labor Code of the Philippines, Annotated Labor Standards & Social Legislation Volume I of a 3-Volume Series 2019 Edition (3rd Revised Edition)
 

 
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UNITED STATES SUPREME COURT JURISPRUDENCE
 

 
PHILIPPINE SUPREME COURT JURISPRUDENCE
 

   
July-1997 Jurisprudence                 

  • G.R. No. 96649-50 July 1, 1997 - PEOPLE OF THE PHIL. v. LYNDON V. MACOY

  • G.R. No. 109660 July 1, 1997 - PEOPLE OF THE PHIL. v. ROMEO NELL

  • G.R. No. 124914 July 2, 1997 - JESUS UGADDAN v. COURT OF APPEALS, ET AL.

  • G.R. No. 123074 July 4, 1997 - PEOPLE OF THE PHIL. v. FERNANDO M. FERNANDEZ

  • Adm. Matter No. MTJ-94-1017 July 7, 1997 - OSCAR B. LAMBINO v. AMADO A. DE VERA

  • Adm. Matter No. P-97-1245 July 7, 1997 - BENIGNO G. GAVIOLA v. NOEL NAVARETTE

  • G.R. No. 105760 July 7, 1997 - PNB v. COURT OF APPEALS, ET AL.

  • G.R. No. 107193 July 7, 1997 - EUGENIO TENEBRO v. COURT OF APPEALS, ET AL.

  • G.R. No. 112006 July 7, 1997 - PEOPLE OF THE PHIL. v. ROBERTO S. DE VERA

  • G.R. No. 114275 July 7, 1997 - IÑIGO F. CARLET v. COURT OF APPEALS, ET AL.

  • G.R. No. 116962 July 7, 1997 - MARIA SOCORRO CACA v. COURT OF APPEALS, ET AL.

  • G.R. Nos. 118940-41 & 119407 July 7, 1997 - PEOPLE OF THE PHIL. v. GREGORIO MEJIA, ET AL.

  • G.R. No. 119872 July 7, 1997 - REMEDIOS NAVOA RAMOS v. COURT OF APPEALS, ET AL.

  • G.R. No. 122206 July 7, 1997 - RAFAEL ARCEGA, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 105284 July 8, 1997 - PEOPLE OF THE PHIL. v. IGNACIO ZUMIL

  • G.R. No. 106099 July 8, 1997 - PEOPLE OF THE PHIL. v. AGUSTIN SOTTO, ET AL.

  • G.R. No. 109814 July 8, 1997 - PEOPLE OF THE PHIL. v. FERNANDO MAALAT

  • G.R. No. 112797 July 8, 1997 - PEOPLE OF THE PHIL. v. NIDA ALEGRO

  • G.R. No. 114265 July 8, 1997 - PEOPLE OF THE PHIL. v. GREGORIO MAGALLANES

  • G.R. No. 115307 July 8, 1997 - MANUEL LAO v. COURT OF APPEALS, ET AL.

  • G.R. No. 115703 July 8, 1997 - EPIFANIO L. CASOLITA, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 117501 July 8, 1997 - SOLID HOMES, INC. v. COURT OF APPEALS, ET AL.

  • G.R. No. 122308 July 8, 1997 - PURITA S. MAPA, ET AL. v. COURT OF APPEALS, ET AL.

  • Adm. Matter No. SC-96-1 July 10, 1997 - DAMASO S. FLORES v. BERNARDO P. ABESAMIS

  • Adm. Matter No. P-97-1236 July 11, 1997 - MADONNA MACALUA v. DOMINGO TIU, JR.

  • Adm. Matter No. P-97-1249 July 11, 1997 - PACITA SY TORRES v. FROILAN S. CABLING

  • G.R. No. 104865 July 11, 1997 - PEOPLE OF THE PHIL. v. VICTORIANO PONTILAR, JR.

  • G.R. Nos. 113511-12 July 11, 1997 - PEOPLE OF THE PHIL. v. DANILO SINOC

  • G.R. No. 115033 July 11, 1997 - PONCIANO T. MATANGUIHAN, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 123204 July 11, 1997 - NATIONWIDE SECURITY AND ALLIED SERVICES, INC. v. NLRC, ET AL.

  • Adm. Matter No. P-95-1158 July 14, 1997 - EUFEMIA BERCASIO v. HERBERTO BENITO, ET AL.

  • G.R. No. 106153 July 14, 1997 - FLORENCIO G. BERNARDO v. COURT OF APPEALS, ET AL.

  • G.R. No. 108838 July 14, 1997 - PAGCOR v. COURT OF APPEALS, ET AL.

  • G.R. Nos. 116528-31 July 14, 1997 - PEOPLE OF THE PHIL. v. MARIETO ADORA

  • G.R. No. 108492 July 15, 1997 - PEOPLE OF THE PHIL. v. NOEL BANIEL, ET AL.

  • G.R. No. 118078 July 15, 1997 - PEOPLE OF THE PHIL. v. OSCAR VILLANUEVA

  • G.R. No. 123379 July 15, 1997 - BAROTAC SUGAR MILLS, INC. v. COURT OF APPEALS, ET AL.

  • G.R. Nos. 115439-41 July 16, 1997 - PEOPLE OF THE PHIL. v. SANDIGANBAYAN, ET AL.

  • G.R. Nos. 120437-41 July 16, 1997 - PEOPLE OF THE PHIL. v. ARMANDO ALVARIO

  • Adm. Matter No. RTJ-97-1382 July 17, 1997 - REXEL M. PACURIBOT v. RODRIGO F. LIM, JR.

  • G.R. No. 105002 July 17, 1997 - PEOPLE OF THE PHIL. v. DIARANGAN DANSAL

  • G.R. No. 108634 July 17, 1997 - ANTONIO P. TAN v. COURT OF APPEALS, ET AL.

  • G.R. No. 111165 July 17, 1997 - PEOPLE OF THE PHIL. v. ROGELIO MERCADO, ET AL.

  • G.R. No. 113257 July 17, 1997 - PEOPLE OF THE PHIL. v. JOHNNY LASCOTA

  • G.R. No. 114742 July 17, 1997 - CARLITOS E. SILVA v. COURT OF APPEALS, ET AL.

  • G.R. No. 118860 July 17, 1997 - ROLINDA B. PONO v. NLRC, ET AL.

  • G.R. No. 120262 July 17, 1997 - PAL, INC. v. COURT OF APPEALS, ET AL.

  • G.R. No. 125195 July 17, 1997 - SAMAHAN NG MGA MANGGAGAWA SA BANDOLINO, ET AL. v. NLRC, ET AL.

  • Adm. Matter No. RTJ-96-1362 July 18, 1997 - DSWD, ET AL. v. ANTONIO M. BELEN, ET AL.

  • Adm. Matter No. RTJ-95-1283 July 21, 1997 - DAVID C. NAVAL, ET AL. v. JOSE R. PANDAY, ET AL.

  • G.R. No. 108488 July 21, 1997 - PEOPLE OF THE PHIL. v. RODENCIO NARCA, ET AL.

  • G.R. No. 111002 July 21, 1997 - PACIFIC MARITIME SERVICES, INC., ET AL. v. NICANOR RANAY, ET AL.

  • G.R. No. 117402 July 21, 1997 - PEOPLE OF THE PHIL. v. ROLLIE L. ALVARADO

  • G.R. No. 119184 July 21, 1997 - HEIRS OF FELICIDAD CANQUE v. COURT OF APPEALS, ET AL.

  • G.R. No. 121768 July 21, 1997 - PEOPLE OF THE PHIL. v. DOMINGO CASTILLO, JR.

  • G.R. Nos. 122250 & 122258 July 21, 1997 - EDGARDO C. NOLASCO v. COMELEC, ET AL.

  • G.R. No. 124347 July 21, 1997 - CMS STOCK BROKERAGE, INC. v. COURT OF APPEALS, ET AL.

  • G.R. No. 125510 July 21, 1997 - PEOPLE OF THE PHIL. v. RENATO LISING

  • G.R. No. 111933 July 23, 1997 - PLDT v. NLRC, ET AL.

  • G.R. Nos. 112429-30 July 23, 1997 - PEOPLE OF THE PHIL. v. RODOLFO P. CAYETANO

  • G.R. Nos. 118736-37 July 23, 1997 - PEOPLE OF THE PHIL. v. TANG WAI LAN

  • Adm. Matter No. P-96-1205 July 24, 1997 - OSCAR P. DE LOS REYES v. ESTEBAN H. ERISPE, JR.

  • Adm. Matter No. RTJ-97-1383 July 24, 1997 - JOSE LAGATIC v. JOSE PEÑAS, JR., ET AL.

  • G.R. No. 104663 July 24, 1997 - PEOPLE OF THE PHIL. v. DAVID SALVATIERRA

  • G.R. No. 105004 July 24, 1997 - PEOPLE OF THE PHIL. v. DIONISIO MAROLLANO

  • G.R. No. 107723 July 24, 1997 - EMS MANPOWER & PLACEMENT SERVICES v. NLRC, ET AL.

  • G.R. No. 111211 July 24, 1997 - ABS-CBN EMPLOYEES UNION, ET AL., v. NLRC, ET AL.

  • G.R. No. 113235 July 24, 1997 - VICTORINA MEDINA, ET AL. v. CITY SHERIFF, MANILA, ET AL.

  • G.R. Nos. 113366-68 July 24, 1997 - GREGORIO ISABELO, ET AL. v. NLRC, ET AL.

  • G.R. No. 116635 July 24, 1997 - CONCHITA NOOL, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 116736 July 24, 1997 - PEOPLE OF THE PHIL. v. BENJAMIN ORTEGA, ET AL.

  • G.R. No. 118458 July 24, 1997 - PEOPLE OF THE PHIL. v. RICKY DELA CRUZ

  • G.R. No. 120276 July 24, 1997 - SINGA SHIP MANAGEMENT PHILS., INC. v. NLRC, ET AL.

  • G.R. No. 121075 July 24, 1997 - DELTA MOTORS CORP. v. COURT OF APPEALS, ET AL.

  • G.R. No. 121867 July 24, 1997 - SMITH KLINE & FRENCH LAB., LTD. v. COURT OF APPEALS, ET AL.

  • G.R. No. 127262 July 24, 1997 - HUBERT WEBB, ET AL. v. PEOPLE OF THE PHIL., ET AL.

  • Adm. Matter Nos. 95-6-55-MTC & P-96-1173 July 28, 1997 - REPORT ON AUDIT IN THE MTC OF PEÑARANDA, NUEVA ECIJA

  • G.R. No. 102858 July 28, 1997 - DIRECTOR OF LANDS v. COURT OF APPEALS, ET AL.

  • G.R. No. 103209 July 28, 1997 - APOLONIO BONDOC, ET AL. v. NLRC, ET AL.

  • G.R. No. 110823 July 28, 1997 - PEOPLE OF THE PHIL. v. ROCHEL TRAVERO

  • G.R. No. 112323 July 28, 1997 - HELPMATE, INC. v. NLRC, ET AL.

  • G.R. No. 113344 July 28, 1997 - PEOPLE OF THE PHIL. v. ATANACIO LUTO

  • G.R. No. 116668 July 28, 1997 - ERLINDA A. AGAPAY v. CARLINA V. PALANG, ET AL.

  • G.R. No. 116726 July 28, 1997 - PEOPLE OF THE PHIL. v. LEONARDO P. DE LA CRUZ

  • G.R. No. 118822 July 28, 1997 - G.O.A.L., INC. v. COURT OF APPEALS, ET AL.

  • G.R. No. 119000 July 28, 1997 - ROSA UY v. COURT OF APPEALS, ET AL.

  • G.R. No. 119649 July 28, 1997 - RICKY GALICIA, ET AL. v. NLRC, ET AL.

  • G.R. No. 119868 July 28, 1997 - PAL, INC. v. NLRC, ET AL.

  • G.R. No. 120072 July 28, 1997 - PEOPLE OF THE PHIL. v. FLORENTINO I. MESA

  • G.R. No. 123361 July 28, 1997 - TEOFILO CACHO v. COURT OF APPEALS, ET AL.

  • G.R. No. 126556 July 28, 1997 - NELSON C. DAVID v. COURT OF APPEALS, ET AL.

  • G.R. No. 117742 July 29, 1997 - GEORGE M. TABERRAH v. NLRC, ET AL.

  • SBC Case No. 519 July 31, 1997 - PATRICIA FIGUEROA v. SIMEON BARRANCO, JR.

  • G.R. No. 97369 July 31, 1997 - P.I. MANPOWER PLACEMENTS, INC. v. NLRC, ET AL.

  • G.R. No. 99030 July 31, 1997 - PLDT v. NLRC, ET AL.

  • G.R. No. 106582 July 31, 1997 - PEOPLE OF THE PHIL. v. RUPERTO BALDERAS

  • G.R. No. 107802 July 31, 1997 - PEOPLE OF THE PHIL. v. JASON NAREDO

  • G.R. No. 108399 July 31, 1997 - RAFAEL M. ALUNAN III, ET AL. v. ROBERT MIRASOL, ET AL.

  • G.R. No. 108619 July 31, 1997 - EPIFANIO LALICAN v. FILOMENO A. VERGARA, ET AL.

  • G.R. No. 113689 July 31, 1997 - PEOPLE OF THE PHIL. v. FELIPE SANGIL, SR.

  • G.R. No. 113958 July 31, 1997 - BANANA GROWERS COLLECTIVE, ET AL. v. NLRC, ET AL.

  • G.R. No. 116060 July 31, 1997 - PEOPLE OF THE PHIL. v. CLEMENTE DE LA PEÑA

  • G.R. No. 116292 July 31, 1997 - PEOPLE OF THE PHIL. v. JIMMY PEÑERO

  • G.R. No. 119068 July 31, 1997 - PEOPLE OF THE PHIL. v. DANTE CASTRO, ET AL.

  • G.R. No. 121027 July 31, 1997 - CORAZON DEZOLLER TISON, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 121157 July 31, 1997 - HEIRS OF SEGUNDA MANINGDING, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 123561 July 31, 1997 - DELIA R. NERVES v. CSC, ET AL.

  • G.R. No. 124678 July 31, 1997 - DELIA BANGALISAN, ET AL. v. COURT OF APPEALS, ET AL.

  •  





     
     

    G.R. No. 119649   July 28, 1997 - RICKY GALICIA, ET AL. v. NLRC, ET AL.

     
    PHILIPPINE SUPREME COURT DECISIONS

    SECOND DIVISION

    [G.R. No. 119649. July 28, 1997.]

    RICKY GALICIA, ANTHONY GALICIA, YOVITO GAN, PRIMO VELEZ, ERBIE GAN, ARTURO ROSAL, ALIPIO GADON, MAXIMINO PANDO, GINA GAN, RODOLFO GALICIA, JESSIE GALICIA, JOEL GREGORIO, CHARLIE GAN, MABINI GUYO, JELRY MERANO, ARNULFO MESANA, ROSENDO GUARDIAN, SOCRATES GALOS, MICHAEL GREGORIO, ROBERTO PALACIO, ROMEO GALICIA, JOEVIN MELANO, PASCUALITO ABAT, PEPITO DAVID and JOVENCIO GREGORIO, Petitioners, v. NATIONAL LABOR RELATIONS COMMISSION (SECOND DIVISION), GLOBE PAPER MILLS/KENG HUA PAPER PRODUCTS, INC. and ARMOR INDUSTRIAL CORPORATION, Respondents.

    Alfredo L. Bentulan, for Petitioners.

    SYNOPSIS


    On January 1992, ninety-five workers, including the twenty petitioners herein were assisted by labor federation, the National Organization of Working Men (NOWM) in their suit against respondent companies for illegal dismissal, regularization, underpayment of wages, holiday day, premium pay, etc. On January 15, 1994, the Labor Arbiter rendered his decision declaring the complainants as regular employees of herein respondents and ordered their reinstatements. In addition thereto, private respondents were ordered to pay back wages amounting to P3,223,261.00.

    Respondent companies appealed to the NLRC. However, during the pendency of the case, NOWM, through its president entered a compromise agreement with private respondents and submitted it before the Commission. The agreement settled the case for and in consideration of the total sum of P300,000.00. The Commission approved the compromise agreement and set aside the Labor Arbiter’s decision. Consequently thereto, herein petitioners filed a petition for Certiorari questioning the validity of the compromise agreement and quitclaim executed by both parties.

    The Supreme Court ruled that the compromise agreement entered into were invalid due to the fact that the total amount of P300,000.00 as consideration for the quitclaims signed by the workers are inordinately low and exceedingly unreasonable compared to P107,480.00 per worker and total P3,223,261.00 awarded by the Labor Arbiter. The Court takes cognizance of the low regard for quitclaims executed by laborers, which are often frowned upon as being contrary to public policy. In view thereof, the assailed resolution and decision of respondent Commission are set aside and remanded to the Commission for expeditious resolution on the merits.


    SYLLABUS


    1. LABOR AND SOCIAL LEGISLATION; EMPLOYMENT DISPUTES; COMPROMISE AGREEMENT AND QUITCLAIMS, DISCUSSED. — A compromise agreement is executed by parties who adjust their difficulties by mutual consent in order to prevent or to put an end to a lawsuit. Additionally, each of the parties is motivated by "the hope of gaining, balanced by the danger of losing." Under the Labor Code, any compromise settlement voluntarily agreed upon by the parties with the assistance of the Bureau of Labor Relations or the regional office of the Department of Labor and Employment shall be final and binding upon the parties. Even if contracted without the assistance of labor officials, compromise agreement between workers and their employers have been upheld and considered as valid accepted and even desirable means of settling disputes. This Court takes cognizance of the low regard for quitclaims executed by laborers, which are often frowned upon as being contrary to public policy. In some cases, we have ruled that quitclaims are ineffective in barring recovery for the full measure of the worker’s rights and that acceptance of benefits there from does not amount to estoppel. In the case of Periquet v. NLRC, however, we set the guidelines and current doctrinal policy regarding quitclaims and waivers. Hence, quitclaims where the workers voluntary accept a reasonable amount or consideration as settlement, are deemed valid and cannot be set aside merely because the parties have subsequently changed their minds. And for the compromise to be voluntarily entered into, there must be personal and specific individual consent.

    2. ID.; ID.; ID.; NOT VALID WHERE CONSIDERATION IS PALPABLY INEQUITABLE. — The more relevant inquiry is whether the consideration for the quitclaims signed by the workers was reasonable and acceptable. Where it is shown that the person making the waiver did so voluntarily and with full understanding of what he was doing and the consideration of the quitclaim is credible, the transaction must be recognized as a valid and binding undertaking. Here, the amount accepted by petitioners was very much less than the amount awarded by the Labor Arbiter. The consideration for the quitclaim, a measly P12,000.00 per worker and the total sum of P300 000.00. are inordinately low and exceedingly unreasonable relative to the P107,380.00 per worker and total P3,223,261.00 awarded by the Arbiter. Palpably inequitable, the quitclaim cannot be considered an obstacle to the pursuit of their legitimate claims. Petitioners never accepted as full compensation the meager amount they received when they signed the quitclaim and release. In the Sinumpaang Salaysay they executed the next day they expressly declared their awareness that the amount they received was unjust and insufficient to answer for their just claims and the award given by the Labor Arbiter, but due to destitution caused by their protracted unemployment, they decided to accept the P12,000.00 in the meantime. The Court also recognizes "direnecessity" of laborers as ample justification to accept even insufficient sums of money from their employers.


    D E C I S I O N


    ROMERO, J.:


    In the instant petition for certiorari assailing the Decision and Resolution of the National Labor Relations Commission in NLRC NCR Case No. 00-01-0017092, dated November 29, 1994 and March 3, 1995, respectively, the sole issue pertains to the validity of a compromise agreement and quitclaims executed by the parties during the pendency of private respondents’ appeal to the respondent Commission.

    On January 8, 1992, ninety-five workers, including the twenty-five petitioners herein, were assisted by a labor federation, the National Organization of Workingmen (NOWM) in their suit against respondent companies for illegal dismissal, regularization, underpayment of wages, holiday pay, premium pay etc. After several complainants withdrew from the case, the parties filed their respective position papers. They alleged that Armor Industrial Corporation, Gibson Contractor Services, Juner Contractor Services, Libra Manpower Agency and Anjo Contractor, all "labor-only" contractors, recruited them and supplied them to Globe Paper Mills and Keng Hua Paper Products where they performed activities directly necessary to the companies’ principal business.

    On January 15, 1994, Labor Arbiter Ernesto S. Dinopol rendered his decision declaring the thirty remaining complainants as regular employees of Keng Hua Paper Products, Globe Paper Mills and Armor Industrial Corporation and ordering their reinstatement. Respondent companies were ordered to pay backwages from February 15, 1991 up to the date of actual reinstatement, in the total amount of P3,223,261.00, with P107,380.00 for each complainant as of January 15, 1994.

    Respondent Companies appealed the case of the NLRC.

    On March 1, 1994, the disputed Compromise Agreement was executed by James Yu, the Manager and Vice President of Globe Paper Mills and Teofilo Rafols, the National President of the National Organization of Workingmen (NOWM) representing the complainants, when most of the latter were still in Romblon, their home province. The agreement settled the case for and in consideration of the total sum of P300,000.00.

    Complainants arrived from Romblon on March 7, 1994. The next day, each of the complainants signed a Quitclaim and Release which confirmed the compromise agreement as well as receipt of their individual share amounting to P12,000.00 each. 1 The standard Quitclaim and Release reads, in part:jgc:chanrobles.com.ph

    "Na, pagsaalang-alang sa halagang LABING DALAWANG LIBONG (P12,000.00) PESOS bilang kabayaran sa akin ng Globe Paper Mills Corp./Armor Industrial Corporation et. al., sa pamamagitan ni Bro. Teofilo A. Rafols, presidente ng N.O.W.M. na siyang aking/aming pinagkatiwalaan ang pakikipag-usap kay G. JAMES YU, President/General Manager ng nasabing mga Kompanya tungkol sa pakikipag-ayos o "amicable settlement," na ang huling ALOK ng Kompanya ay aking sinang-ayunan, dala na rin ng aking kahirapan at kawalan ng pinagkakitaan sa matagal na panahon;" (Emphasis supplied.) 2

    On March 9, 1994, petitioners executed a Sama-samang Sinumpaang Salaysay where they stated:jgc:chanrobles.com.ph

    "4. Na, batid namin na ang naturang halaga na aming tinanggap (P12,000.00 each) ay hindi makatarungan at sapat na kabayaran sa aming mga hinahabol na biyaya sa naturang mga Kompanya at alinsunod sa desisyon ng Labor Arbiter, ngunit, dala ng aming kahirapan sa buhay, bunga ng aming matagal nang pagkakatanggal sa aming trabaho mula pa noong taon 1991 at 1992 ay napag-pasiyahan namin na pansamantalang kunin/tanggapin ang inalok na halaga ng Kompanya, ngunit aming ipagpapatunay ang nasabing usapin/asunto sa kadahilanan masyado kaming api at hindi makatarungan ang pagkakatanggap sa aming trabaho na nagdulot ng labis na kahirapan sa aming mga mahal sa buhay, sa katunayan, ang aming kinabubuhay ay sa tulong ng aming mga malalapit na kamag-anak at mga kaibigan, at upang lubusang mabigyan ng katarungan ang aming kalagayan." (Emphasis added.) 3chanrobles virtual lawlibrary

    Private respondents submitted the Compromise Agreement and Joint Motion to Dismiss before the respondent Commission which was then considering the case on appeal from the decision of the Labor Arbiter. Herein petitioners later filed an Opposition to the Motion to Dismiss where they demanded the difference of what they actually received and the judgment award in their favor.

    On November 29, 1994, respondent Commission rendered its Decision approving the Compromise Agreement, setting aside the January 15, 1994 decision of the Labor Arbiter and dismissing the instant case. 4 The NLRC held that the complainants were fully aware of the award in their favor dated January 15, 1994 when they voluntarily entered into the compromise agreement on March 1, 1994. They thus disregarded the judgment award and opted for the last and sincere offer of respondent Globe Paper Mills instead of waiting out the appeal filed by respondents. Respondent NLRC added that it cannot subscribe to complainants’ contention that they signed the compromise agreement under the compulsion of "dire necessity" and held that position as a mere afterthought.

    Their motion for reconsideration having been denied on March 3, 1995, the instant petition for certiorari was filed contesting the decision of the NLRC.

    A compromise agreement is executed by parties who adjust their difficulties by mutual consent in order to prevent or to put an end to a lawsuit. Additionally, each of the parties is motivated by "the hope of gaining, balanced by the danger of losing." 5 Under the Labor Code, any compromise settlement voluntarily agreed upon by the parties with the assistance of the Bureau of Labor Relations or the regional office of the Department of Labor and Employment shall be final and binding upon the parties. 6 Even if contracted without the assistance of labor officials, compromise agreements between workers and their employers have been upheld and considered as valid, accepted and even desirable means of settling disputes. 7

    This Court takes cognizance of the low regard for quitclaims executed by laborers, which are often frowned upon as being contrary to public policy. 8 In some cases, we have ruled that quitclaims are ineffective in barring recovery for the full measure of the worker’s rights and that acceptance of benefits therefrom does not amount to estoppel. 9 In Lopez Sugar Corporation v. Federation of Free Workers, the Court explained:jgc:chanrobles.com.ph

    "Acceptance of those benefits would not amount to estoppel. The reason is plain. Employer and employee, obviously do not stand on the same footing. The employer drove the employee to the wall. The latter must have to get hold of money. Because, out of job, he had to face the harsh necessities of life. He thus found himself in no position to resist money proffered. His, then, is a case of adherence, not of choice. One thing, sure however, is that petitioners did not relent their claim. They pressed it. They are deemed not to have waived any of their rights." 10

    In the case of Periquet v. NLRC, we set the guidelines and current doctrinal policy regarding quitclaims and waivers, thus:jgc:chanrobles.com.ph

    "Not all waivers and quitclaims are invalid as against public policy. If the agreement was voluntarily entered into and represents a reasonable settlement, it is binding on the parties and may not later be disowned simply because of a change of mind. It is only where there is clear proof that the waiver was wangled from an unsuspecting or gullible person, or the terms of settlement are unconscionable on its face, that the law will step in to annul the questioned transaction. But where it is shown that the person making the waiver did so voluntarily, with full understanding of what he was doing, and the consideration for the quitclaim is credible and reasonable, the transaction must be recognized as a valid and binding undertaking." 11

    Hence, quitclaims were the workers voluntarily accept a reasonable amount or consideration as settlement, are deemed valid and cannot be set aside merely because the parties have subsequently change their minds.

    For the compromise to be voluntarily entered into, there must be personal and specific individual consent. 12 In the case at bar, petitioners attempt to disavow their consent given to Mr. Teofilo Rafols, president of the National Organization of Workingmen, by disclaiming any authority accorded by them to Mr. Rafols to fix and decide the total amount. 13 We find no basis for this allegation apart from their joint affidavit and unsubstantiated claims to that effect.

    Although their authorization in favor of Mr. Rafols does not appear to have been recorded in a written instrument for no such document was submitted to the Court, at the conference between the parties, they confirmed the veracity of the compromise agreement and the quitclaim. Even granting that there may have been some question regarding the authority granted to the NOWM President, the same was waived once petitioners signed the quitclaim evidencing receipt of their individual shares.

    Respondent Commission has ruled that petitioners authorized NOWM to negotiate with management. It cannot be said to have committed grave abuse of discretion in utilizing facts presented during the conference, for proceedings held thereat do not constitute privileged communication.

    The more relevant inquiry is whether the consideration for the quitclaims signed by the workers was reasonable and acceptable. Where it is shown that the person making the waiver did so voluntarily and with full understanding of what he was doing and the consideration of the quitclaim is credible, the transaction must be recognized as a valid and binding undertaking. 14

    We find quite relevant the ruling of the Court in Cruz v. NLRC 15 because the amount accepted by petitioners herein was very much less than the amount awarded by the Labor Arbiter in his January 15, 1994 decision. The consideration for the quitclaim, a measly P12,000.00 per worker and the total sum of P300,000, are inordinately low and exceedingly unreasonable relative to the P107,380.00 per worker and total P3,223,261.00 awarded by the Arbiter. Palpably inequitable, the quitclaim cannot be considered an obstacle to the pursuit of their legitimate claims. 16

    Petitioners never accepted as full compensation the mere amount they received when they signed the quitclaim and release. In the Sinumpaang Salaysay they executed the next day, they expressly declared their awareness that the amount they received was unjust and insufficient to answer for their just claims and the award given by the Labor Arbiter, but due to destitution caused by their protracted unemployment, they decided to accept the P12,000.00 in the meantime. 17 The Court also recognizes "dire necessity" of laborers as ample justification to accept even insufficient sums of money from their employers. We are not unaware that in some cases, such as Olaybar v. NLRC, this ground was deemed unacceptable in refuting the agreement in question. The main difference, however, lies in the existence of a voluntary acceptance of the agreement and the reasonable consideration for it, making the agreement intrinsically valid and binding, thus rendering the "dire necessity" excuse immaterial and irrelevant.chanrobles.com : virtual lawlibrary

    Worth noting is the Solicitor General’s opinion in favor of granting the petition. The OSG concluded that" (w)hile petitioners may not have been ‘tricked’ into accepting the P12,000.00, to repeat, the undisputed and concurrent circumstances of dire necessity and unconscionability obtaining in the case at bar constitute more than sufficient ground to invalidate the compromise agreement." 18

    WHEREFORE, the instant petition is hereby GRANTED. The assailed resolution and decision of respondent Commission are hereby SET ASIDE. The case is REMANDED to the Commission for expeditious resolution on the merits.

    SO ORDERED.

    Regalado, Puno and Mendoza, JJ., concur.

    Torres, Jr., J., is on leave.

    Endnotes:



    1. The remaining five complainants below had already voluntarily resigned.

    2. Rollo, pp. 57-58.

    3. Rollo, p. 66.

    4. "National Organization of Workingmen (NOWM) and its members, Ricky Galicia, Et. Al. v. Globe Paper Mills, Keng Hua Paper Products, Inc. Armor Industrial Corporation, Gibson Contractor Agency, Libra Manpower Agency, Anjo Contractor Services and Juner Contractor Services," Per Commissioner Raul T. Aquino, with the concurrence of Commissioners Victoriano R. Calaycay and Rogelio I. Rayala, Rollo, pp. 24-35.

    5. David v. CA, 214 SCRA 644 (1992) and Rovero v. Amparo, 91 Phil. 228 (1952) in Reformist Union of R.B. Liner, Inc. v. NLRC, G.R. No. 120482, January 27, 1997.

    6. Article 227.

    7. Morales v. NLRC, 241 SCRA 103 (February 6, 1995), Victorias Milling Co. Inc. v. NLRC, 233 SCRA 403 (1994).

    8. Republic Planters Bank v. NLRC, G.R. No. 117460, January 6, 1997 citing Philippine National Construction Corporation v. NLRC, 215 SCRA 204 (October 27, 1992).

    9. Ibid., citing Medina v. Consolidated Broadcasting System, 222 SCRA 707 (May 28, 1993) and Blue Bar Coconut Phils., Inc. v. 208 SCRA 371 (May 5, 1992).

    10. 189 SCRA 192 (August 30, 1990) citing Cariño v. ACCFA, 18 SCRA 183 (September 29, 1966).

    11. 186 SCRA 724 (June 22, 1990).

    12. General Rubber v. Drilon, 169 SCRA 808; Republic v. NLRC, 244 SCRA 564 (May 31, 1995).

    13. Petition p. 11; Rollo, p. 16 and their Joint Affidavit dated January 13, 1995, Rollo, p. 78.

    14. Olaybar v. NLRC, 237 SCRA 819 (October 28, 1994).

    15. 203 SCRA 286 (October 28, 1991).

    16. Ibid.

    17. See their Sinumpaang Salaysay, Rollo, p. 66, quoted on page 3.

    18. Comment of the OSG, p. 9, Rollo, p. 115.

    G.R. No. 119649   July 28, 1997 - RICKY GALICIA, ET AL. v. NLRC, ET AL.


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