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SUPREME COURT REPORTS ANNOTATED VOLUME 748

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Case Title:
ANNOTATION
Citation: 748 SCRA 687 ANNOTATION
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LACONIC RULES ON WAIVERS AND QUITCLAIMS
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by

MAURICIO C. ULEP*

___________________

§ 1. The law on compromise settlement in labor


cases,
p. 688
§ 2. Related labor laws under the 1987
Constitution,
p. 689
§ 3. Related labor laws under the New Civil Code,
p. 690
§ 4. Related labor laws under the Revised Penal
Code,
p. 691
§ 5. Quitclaim and Waiver defined, p. 692
§ 6. Requisites of a valid quitclaim, p. 692
§ 7. Standards for determining the validity of a
Waiver and Quitclaim, p. 693
§ 8. Guidelines for a valid and enforceable
quitclaim,
p. 694
§ 9. Form copy of the Quitclaim and Release used
by the National Labor Relations Commission, p. 695
§ 10. Quitclaims are often frowned upon as
contrary to public policy, p. 696
§ 11. Not all quitclaims are against public policy,
p. 697

_______________

* Former Associate Dean, UE College of Law; Professor of Law;


Author of Law Books; former President, IBP Manila Chapter III.

688

688 SUPREME COURT REPORTS ANNOTATED


Laconic Rules on Waivers and Quitclaims

§ 12. An employee who resigns and executes a


quitclaim is generally stopped from filing further
money claims, p. 698
§ 13. Who has the burden of proof in showing that
a quitclaim was voluntarily executed, p. 698
§ 14. To be valid, waivers and quitclaims must be
couched in clear terms, p. 699
§ 15. Dire necessity is not a ground for annulling

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a quitclaim, p. 700
§ 16. Quitclaims do not stop employees from
pursuing their claims arising from unfair labor
practice. Reason, p. 700
§ 17. Quitclaims signed by migrant workers are
viewed with strong disfavor, p. 702
§ 18. A quitclaim where an employee agrees to
receive less than what the law provides, is void, p.
702
§ 19. Procedural matter, p. 703

___________________

„Renuntiatio nonpraesumitur.‰ (A waiver of rights is not


presumed). (ACD Investigation Security Agency, Inc. v.
Daquera, 426 SCRA 494, 501 [2004])

§ 1. The law on compromise settlement in labor


cases
Article 227. Any compromise settlement, including
those involving labor standard laws, voluntarily agreed
upon by the parties with the assistance of the Bureau or
the regional office of the Department of Labor, shall be
final and binding upon the parties. The National Labor
Relations Commission or any court, shall not assume
jurisdiction over issues involved therein except in case of
noncompliance thereof or if there is prima facie evidence
that the settlement was obtained through fraud,
misrepresentation or coercion. (Labor Code of the
Philippines)

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Laconic Rules on Waivers and Quitclaims

§ 2. Related labor laws under the 1987


Constitution
Section 18. The State affirms labor as a primary social
economic force. It shall protect the rights of workers and
promote their welfare. (Article II)
x x x   x x x   x x x
Section 12. The State shall promote the preferential
use of Filipino labor, domestic materials and locally
produced goods, and adopt measures that help make them
competitive. (Article XII)
x x x   x x x   x x x
Section 3. The State shall afford full protection to
labor, local and overseas, organized and unorganized, and
promote full employment and equality of employment
opportunities for all.
It shall guarantee the rights of all workers to self-
organization, collective bargaining and negotiations, and
peaceful concerted activities, including the right to strike
in accordance with law. They shall be entitled to security of
tenure, humane conditions of work, and a living wage.
They shall also participate in policy and decision-making
processes affecting their rights and benefits as may be
provided by law.
The State shall promote the principle of shared
responsibility between workers and employers and the

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preferential use of voluntary modes in settling disputes,
including conciliation, and shall enforce their mutual
compliance therewith to foster industrial peace.
The State shall regulate the relations between workers
and employers, recognizing the right of labor to its just
share in the fruits of production and the right of
enterprises to reasonable returns to investments, and to
expansion and growth. (Article XIII)

690

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§ 3. Related labor laws under the New Civil Code


Article 6. Rights may be waived, unless the waiver is
contrary to law, public order, public policy, morals, or good
customs, or prejudicial to a third person with a right
recognized by law.
x x x   x x x   x x x
Article 1700. The relations between capital and labor
are not merely contractual. They are so impressed with
public interest that labor contracts must yield to the
common good. Therefore, such contracts are subject to the
special laws on labor unions, collective bargaining, strikes
and lockouts, closed shop, wages, working conditions,
hours of labor and similar subjects.
Article 1701. Neither capital nor labor shall act
oppressively against the other, or impair the interest or
convenience of the public.
Article 1702. In case of doubt, all labor legislation and
all labor contracts shall be construed in favor of the safety
and decent living for the laborer.
Article 1703. No contract which practically amounts
to involuntary servitude, under any guise whatsoever,
shall be valid.
Article 1704. In collective bargaining, the labor union
or members of the board or committee signing the contract
shall be liable for nonfulfillment thereof.
Article 1705. The laborerÊs wages shall be paid in
legal currency.
Article 1706. Withholding of the wages, except for a
debt due, shall not be made by the employer.
Article 1707. The laborerÊs wages shall be a lien on
the goods manufactured or the work done.
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Article 1708. The laborerÊs wages shall not be subject


to execution or attachment, except for debts incurred for
food, shelter, clothing and medical attendance.
Article 1709. The employer shall neither seize nor
retain any tool or other articles belonging to the laborer.
Article 1710. Dismissal of laborers shall be subject to
the supervision of the Government, under special laws.
§ 4. Related labor laws under the Revised Penal
Code
Article 288. Other similar coercions; (Compulsory

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purchase of merchandise and payment of wages by means
of tokens).·The penalty of arresto mayor or a fine ranging
from 200 to 500 pesos, or both, shall be imposed upon any
person, agent or officer, of any association or corporation
who shall force or compel, directly or indirectly, or shall
knowingly permit any laborer or employee employed by
him or by such firm or corporation to be forced or
compelled, to purchase merchandise or commodities of any
kind.
The same penalties shall be imposed upon any person
who shall pay the wages due a laborer or employee
employed by him, by means of tokens or objects other than
the legal tender currency of the laborer or employee.
Article 289. Formation, maintenance and prohibition
of combination of capital or labor through violence or
threats.·The penalty of arresto mayor and a fine not
exceeding 300 pesos shall be imposed upon any person
who, for the purpose of organizing, maintaining or
preventing coalitions or capital or labor, strike of laborers
or lock-out of employees, shall employ violence or threats
in such a degree as to compel or force the laborers or
employers in the free and legal exercise of their industry or
work, if the act shall not constitute a more serious offense
in accordance with the provisions of this Code.
692

692 SUPREME COURT REPORTS ANNOTATED


Laconic Rules on Waivers and Quitclaims

§ 5. Quitclaim and Waiver defined


Quitclaim is defined as a release or acquittance given to
one man by another, in respect of any action that he has or
might have against him. (BlackÊs Law Dictionary, 6th
edition, p. 1251)
Waiver is defined as the relinquishment of a known
right with knowledge of its existence and an intention to
relinquish it. Voluntary choice is the essence of waiver. To
be valid and effective, a waiver must in the first place be
couched in clear and unequivocal terms which leave no
doubt as to the intention of a person to give up a right or
benefit which legally pertains to him. It may not casually
be attributed to a person when the terms thereof do not
explicitly and clearly evidence an intent to abandon a right
vested in such person. (People v. Donato, 198 SCRA 130
[1991]. See also Public Estates Authority v. Bolinao
Security and Investigation Service, Inc., 472 SCRA 165
[2005])
§ 6. Requisites of a valid quitclaim
The requisites of a valid quitclaim are that:
1. there was no fraud or deceit on the part of any of the
parties;
2. the consideration for the quitclaim is credible and
reasonable; and
3. the contract is not contrary to law, public order,
public policy, morals or good customs or prejudicial to a
third person with a right recognized by law. (Soriano, Jr. v.
National Labor Relations Commission, 521 SCRA 526
[2007] citing Danzas Intercontinental, Inc. v. Daguman,
456 SCRA 382 [2005]; Sime Darby Pilipinas, Inc. v.
Arguilla, 490 SCRA 183 [2006]; McLeod v. National Labor

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Relations Commission, 512 SCRA 222 [2007]; Goodrich
Manufacturing Corporation v. Ativo, 611 SCRA 261 [2010];
InterOrient Maritime Enterprises, Inc. v. Remo, 622 SCRA
237 [2010]; Varorient Shipping

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Co., Inc. v. Flores, 632 SCRA 274 [2010]; Jiao v.


National Labor Relations Commission, 670 SCRA 184
[2012]; Zuellig Pharma Corporation v. Sibal, 701 SCRA
165 [2013]; Philippine Carpet Manufacturing Corporation
v. Tagyamon, 712 SCRA 489 [2013])
§ 7. Standards for determining the validity of a
Waiver and Quitclaim
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 questionable 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. (Rizal Commercial Banking Corporation v.
Bithao, 500 SCRA 119 [2006], citing Periquet v. National
Labor Relations Commission, 186 SCRA 724 [1990])
Legitimate waivers that represent a voluntary and
reasonable settlement of laborerÊs claims which should be
so respected by the Court as the law between the parties.
(Magsalin v. National Organization of Working Men, 403
SCRA 199 [2003]; National Federation of Labor v. Court of
Appeals, 440 SCRA 603 [2004]; Mendoza, Jr. v. San Miguel
Foods, Inc., 458 SCRA 664 [2005])
When such quitclaim was made voluntarily and there is
no evidence that the employer was guilty of fraud or
intimidation in obtaining such waiver, its validity must be
upheld. (Casimiro v. Stern Real Estate, Inc., 484 SCRA 463
[2006])
694

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Laconic Rules on Waivers and Quitclaims

Likewise, a quitclaim must be upheld if there is no


disparity between the amount of the quitclaim and the
amount actually due the complainants under the law.
(Acuña v. Court of Appeals, 489 SCRA 658 [2006])
§ 8. Guidelines for a valid and enforceable
quitclaim
In order to prevent disputes on the validity and
enforceability of quitclaims and waivers of employees

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under Philippine Laws, said agreements should contain
the following:
1. A fixed amount as full and final compromise
settlement;
2. The benefits of the employee if possible with the
corresponding amounts, which the employees are giving up
in consideration of the fixed compromise amount;
3. A statement that the employer has clearly explained
to the employee · that by signing the waiver or quitclaim,
they are forfeiting or relinquishing their right to receive
the benefits which are due them under the law; and
4. A statement that the employee signed and executed
the document voluntarily and had fully understood the
contents of the document and that their consent was freely
given without any threat, violence, duress, intimidation or
undue influence exerted on their person. It is advisable
that the stipulations be made in English and Tagalog or in
the dialect known to the employee. There should be two (2)
witnesses to the execution of the quitclaim who must also
sign the quitclaim. The document should be subscribed and
sworn to under oath preferably before any administering
official of the Department of Labor and Employment or its
regional office, the Bureau of Labor Relations, the NLRC
or a labor attaché in a foreign country. Such official shall
assist the parties regarding the execution of the quitclaim
and waiver. This compromise settlement becomes final and
binding under Article 227 of the Labor Code. (EDI-
Staffbuilders International, Inc. v. National Labor
Relations Commission, 537 SCRA 409 [2007])

695

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Laconic Rules on Waivers and Quitclaims

§ 9. Form copy of the Quitclaim and Release used


by the National Labor Relations Commission

REPUBLIC OF THE PHILIPPINES


DEPARTMENT OF LABOR AND EMPLOYMENT
NATIONAL LABOR RELATIONS COMMISSION

QUEZON CITY
CONCILIATION AND MEDIATION

QUITCLAIM AND RELEASE


PAGTALIKOD AT PAGPAPAWALANG SAYSAY
I (Ako), ________________ of legal age (may sapat na
gulang), residing at (nakatira sa)
________________________ for and in consideration of the
amount of (bilang konsiderasyon sa halagang)
_________________ pesos (piso) given to me by (na ibinigay
sa akin ng) _________________, do hereby release and
discharge (ay aking pinapawalang-saysay at tinatalikuran)
aforesaid company/corporation and its officers, person/s
(ang nabanggit na kumpanya/kor​po​rasyon at ang mga
tauhan nito) from any money claims (mula sa anumang
paghahabol na nauukol sa pananalapi) by way of unpaid
wages (sa pamamagitan ng di nabayarang sahod),
separation pay, overtime pay otherwise (o anupaman) as
may be due to me (na karapat-dapat para sa akin) its

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officers/persons (na may kaugnayan sa aking huling
pinapasukang kumpanya o korporasyon at sa mga
opisyales o tauhan nito).
I am executing this quitclaim and release (isinasagawa
ko ang pagtalikod o pagpapapawalang-saysay na ito),
freely and voluntarily (ng may kalayaan at kusang loob)
before this Honorable Office (sa harapan ng marangal na
tanggapang ito) without any force or duress (ng walang
pamimilit o pamumuwersa) and as part of the compromise
agreement reached during the preventive conciliation and
mediation process conducted in the NLRC (at bilang
bahagi ng napagkasun-

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Laconic Rules on Waivers and Quitclaims

duan buhat sa proseso ng „preventive conciliation at


mediation‰ dito sa NLRC).
IN VIEW WHEREOF (DAHIL DITO), I hereunto set my
hand this (akoÊy lumagda ngayong) ___ day of (araw ng)
_____ 200__ in Quezon City (sa Lungsod ng Quezon).
________________________________
Signature of the requesting party
(Lagda ng Partidong Humiling ng Com-Med
Conference)
Signed in the presence of (Nilagdaan sa harapan ni):
_____________________________
Name in Print Below Signature
Limbagin ang pangalan sa ilalim ng lagda
_________________________________________________________
Subscribed and sworn to before me this ___ day of _____
200__ in Quezon City, Philippines.
_____________
Labor Arbiter

§ 10. Quitclaims are often frowned upon as


contrary to public policy
Time honored is the precept that quitclaims are
ineffective in barring recovery for the full measure of the
workerÊs rights and that acceptance of benefits therefrom
does not amount to estoppel. This is consistent with the
constitutional provision that the State affirms labor as a
primary social economic force. It shall protect the rights of
workers and promote their welfare. (Blue Bar Coconut
Philippines, Inc. v. NLRC, 208 SCRA 371 [1992];
Philippine National Construction Corporation v. NLRC,
215 SCRA 204 [1992]; Philippine National Construction
Corporation v. NLRC, 317 SCRA 186 [1999]; Lambo v.
National Labor Relations Commission, 317 SCRA 420
[1999])

697

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Laconic Rules on Waivers and Quitclaims

§ 11. Not all quitclaims are against public policy

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While quitclaims executed by employees are commonly
frowned upon as contrary to public policy and are
ineffective to bar claims for the full measure of the
employeeÊs rights, there are legitimate waivers that
represent a voluntary reasonable settlement of laborerÊs
claims which should be respected by the courts of law as
between the parties and which may not be disowned by the
parties simply because of a change of mind (Veloso v.
Department of Labor and Employment, 200 SCRA 201
[1991]; Alfaro v. Court of Appeals, 363 SCRA 799 [2001];
Aklan v. San Miguel Corporation, 573 SCRA 675 [2008];
Talam v. National Labor Relations Commission, 617 SCRA
408 [2010]; Auza, Jr. v. MOL Philippines, Inc., 686 SCRA
66 [2012]); provided that it constitutes a credible and
reasonable settlement, and that the one accomplishing it
has done so voluntarily and with a full understanding of its
import. (Plastimer Industrial Corporation v. Gopo, 643
SCRA 502 [2011], citing Alabang Country Club, Inc. v.
National Labor Relations Commission, 466 SCRA 329
[2005]; Bilbao v. Saudi Arabian Airlines, 662 SCRA 540
[2011]; Aujero v. Philippine Communications Satellite
Corporation, 663 SCRA 467 [2012]; Ison v. Crewserve, Inc.,
669 SCRA 481 [2012]; Loadstar International Shipping,
Inc. v. Heirs of the Late Enrique C. Calawigan, 687 SCRA
300 [2012]; Zuellig Pharma Corporation v. Sibal, 701
SCRA 165 [2013])
The exceptions are: (1) where there is clear proof that
the waiver was wangled from an unsuspecting or gullible
person, or (2) where the terms of settlement are
unconscionable on their face. (Bogo-Medellin Sugarcane
Planters Association, Inc. v. National Labor Relations
Commission, 296 SCRA 108 [1998]; Gamogamo v. PNOC
Shipping and Transport Corp., 381 SCRA 742 [2002];
Philippine Employ Services and Resources, Inc. v. Paramio,
427 SCRA 732 [2004]; C. Planas Commercial v. National
Labor Relations Commission, 474 SCRA 608 [2005];
Lacuesta v. Ateneo de Manila University, 477 SCRA 217
[2005]; Maricalum Mining Corporation v.

698

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Brion, 482 SCRA 87 [2006]; Catholic Vicariate, Baguio


City v. Sto. Tomas, 548 SCRA 31 [2008]; Hanjin Heavy
Industries and Construction Co., Ltd. v. Ibañez, 555 SCRA
537 [2008]; Morales v. Metropolitan Bank and Trust
Company, 686 SCRA 132 [2012])
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. (Marcos v. National Labor Relations
Commission, 248 SCRA 146 [1995]; Famanila v. Court of
Appeals, 500 SCRA 76 [2006])
§ 12. An employee who resigns and executes a
quitclaim is generally stopped from filing further
money claims
Although the Supreme Court has, more often than not,

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been inclined towards the workers and has upheld their
cause in their conflicts with the employers, such
inclination has not blinded it to the rule that justice is in
every case for the deserving, to be dispensed in the light of
the established facts and applicable law and doctrine. An
employee who resigns and executes a quitclaim in favor of
the employer is generally stopped from filing any further
monetary claims against the employer arising from the
employment. (Bilbao v. Saudi Arabian Airlines, 662 SCRA
540 [2011])
§ 13. Who has the burden of proof in showing that
a quitclaim was voluntarily executed
The burden of proving that the quitclaim or waiver was
voluntarily entered into rests on the employer. (EMCO
Plywood Corporation v. Abelgas, 427 SCRA 496 [2004];
Universal Staffing Services, Inc. v. National Labor
Relations Commission, 559 SCRA 221 [2008]; San Miguel
Corporation v. Teodosio, 602 SCRA 197 [2009])

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In some cases, the Supreme Court consider among


others, the educational attainment of the employees
concerned in upholding the validity of their quitclaims
which they have executed in favor of their employers.
However, in Becton Dickinson Phils., Inc. v. National Labor
Relations Commission, 475 SCRA 123 (2005), the Supreme
Court held: There is no nexus between intelligence, or even
the position which the employee held in the company when
it concerns the pressure which the employer may exert
upon the free will of the employee who is asked to sign a
release and quitclaim. A lowly employee or a sales
manager who is confronted with the same dilemma of
whether signing a release and quitclaim and accept what
the company offers them, or refusing to sign and walk out
without receiving anything, may do succumb to the same
pressure, being very well aware that it is going to take
quite a while before he can recover whatever he is entitled
to, because it is only after a protracted legal battle
starting from the labor arbiter level, all the way to this
Court, can he receive anything whatsoever, coupled with
the probability of not immediately getting any gainful
employment or means of livelihood in the meantime,
constitutes enough pressure upon anyone who is asked to
sign a release and quitclaim in exchange of some amount
of money which may be way below what he may be entitled
to, based on company practice and policy or by law.
(Universal Robina Sugar Milling Corporation
[URSUMCO] v. Caballeda, 560 SCRA 115 [2008])
§ 14. To be valid, waivers and quitclaims must be
couched in clear terms
To be valid and effective, waivers and quitclaims must
be couched in clear and unequivocal terms, leaving no
doubt as to the intention of those giving up a right or a
benefit that legally pertains to them. (Insular Life
Assurance Company, Ltd. v. Asset Builders Corporation,
422 SCRA 148 [2004]; Famanila v. Court of Appeals, 500
SCRA 76 [2006])

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700

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Likewise, the waivers should be carefully examined, in


regard not only to the words and terms used, but also to
the factual circumstances under which they have been
executed. (Land and Housing Development Corporation v.
Esquillo, 471 SCRA 488 [2005])
§ 15. Dire necessity is not a ground for annulling
a quitclaim
It is elementary that a contract is perfected by mere
consent and from that moment, the parties are bound not
only to the fulfillment of what has been expressly
stipulated but also of all the consequences which,
according to their nature, may be in keeping with good
faith, usage and law. Further, dire necessity is not an
acceptable ground for annulling a quitclaim since it has
not been shown that the petitioner was forced to sign it.
(Veloso v. Department of Labor and Employment, 200 SCRA
201 [1991]; Coats Manila Bay, Inc. v. Ortega, 579 SCRA
300 [2009])
§ 16. Quitclaims do not stop employees from
pursuing their claims arising from unfair labor
practice. Reason
Quitclaims, waivers and/or complete releases executed
by the employees do not stop them from pursuing their
claims arising from unfair labor practice · if there is a
showing of undue pressure or duress. The basic reason for
this is that such quitclaims waivers and releases, being
figuratively exacted through the barrel of a gun, are
against public policy and therefore null and void ab initio.
(Urgelio v. Osmeña, Jr., 10 SCRA 253 [1964]; Cariño v.
Agricultural Credit and Cooperative Financing
Administration, 18 SCRA 183 [1966]; Mercury Drug Co.,
Inc. v. Court of Industrial Relations, 56 SCRA 694 [1974];
Firestone Filipinas Employees Association v. Firestone Tire
and Rubber Co. of the Philippines, 61 SCRA 339 [1974];
AFP Mutual Benefit Association, Inc. v. AFP-MBAI-

701

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EU, 97 SCRA 715 [1980]; Agoy v. National Labor


Relations Commission, 252 SCRA 588 [1996]; Anino v.
National Labor Relations Commission, 290 SCRA 489
[1998]; People v. Gomez, 325 SCRA 61 [2000]; JMM
Productions and Management, Inc. v. Court of Appeals, 390
SCRA 223 [2002]; Bay Haven, Inc. v. Abuan, 560 SCRA 457
[2008])
Moreover, deeds of release and quitclaim cannot bar
employees from demanding benefits to which they are
legally entitled or from contesting the legality of their
dismissal and their acceptance of these benefits would not
amount to estoppel. (Galicia v. NLRC [Second Division],
276 SCRA 381 [1997]; EMCO Plywood Corporation v.

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Abelgas, 427 SCRA 496 [2004]; Sime Darby Pilipinas, Inc.
v. Arguilla, 490 SCRA 183 [2006]; Sari-Sari Group of
Companies, Inc. v. Piglas Kamao [Sari-Sari Chapter], 561
SCRA 569 [2008]; Rondina v. Court of Appeals [Former
Special 19th Division], 592 SCRA 346 [2009]; San Miguel
Corporation v. Teodosio, 602 SCRA 197 [2009]; Interorient
Maritime Enterprises, Inc. v. Remo, 622 SCRA 237 [2010];
Londonio v. Bio Research, Inc., 639 SCRA 591 [2011];
Philippine Carpet Manufacturing Corporation v.
Tagyamon, 712 SCRA 489 [2013])
The Supreme Court emphatically gave the reason in one
case:
„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 on their claim. They pressed it. They are
deemed not to have waived any of their rights.‰ (Cariño v.
Agricultural Credit and Cooperative Financing
Administration, 18 SCRA 183, 190 [1966])

702

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Laconic Rules on Waivers and Quitclaims

§ 17. Quitclaims signed by migrant workers are


viewed with strong disfavor
Quitclaims signed by migrant workers such as Letters
of Indemnity, are viewed with strong disfavor. Public policy
dictates that they be presumed to have been executed at
the behest of the employer. Settled is the rule that
quitclaims are ineffective in barring full recovery of the
benefits due the employee. The acceptance of any monetary
benefit, such as repatriation expenses and accrued wages
in this case, would not divest respondents of the right to
fully claim the remainder of what is rightfully due them.
(Oriental Shipmanagement Co., Inc. v. Court of Appeals,
480 SCRA 100 [2006]; Hanjin Heavy Industries and
Construction Co., Ltd. v. Ibañez, 555 SCRA 537 [2008])
This is especially true in a case where instead of
promoting the orderly settlement of disputes, petitionersÊ
acts encouraged the circumvention of the proper legal
procedures and the evasion of the payment of legitimate
claims to a seafarer succumbing to a life threatening
disease. (Inter-Orient Maritime Incorporated v. Candava,
700 SCRA 174 [2013])
§ 18. A quitclaim where an employee agrees to
receive less than what the law provides, is void
Under prevailing jurisprudence, the fact that an
employee has signed a satisfaction receipt of his claims
does not necessarily result in the waiver thereof. The law
does not consider as valid any agreement whereby a
worker agrees to receive less compensation than what he is
entitled to recover. A deed of release or quitclaim cannot
bar an employee from demanding benefits to which he is
legally entitled. (More Maritime Agencies Co., Inc. v.

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NLRC, 307 SCRA 189 [1999]; Lopez Sugar Corporation v.
Franco, 458 SCRA 515 [2005]; Solgus Corporation v. Court
of Appeals, 514 SCRA 522 [2007])

703

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Laconic Rules on Waivers and Quitclaims

Thus, in one case, the Supreme Court held that the


settlement which two employees received since they were
in dire straits at the time they executed a quitclaim was
not reasonable, considering the long years of service that
they had with the company. (See Radio Mindanao
Network, Inc. v. Ybarola, Jr., 680 SCRA 551 [2012])
In another case, the quitclaim that was signed by an
employee was declared void and contrary to public policy
since it included her entitlement to retirement benefits.
(City Government of Makati v. Odeña, 703 SCRA 460
[2013])
§ 19. Procedural matter
The execution of a quitclaim after a decision has become
final and executory is a supervening event which could
affect the decision of the labor arbiter. The quitclaim may
change the situation of the parties because its validity
would determine whether a party may be entitled to the
relief demanded like reinstatement. (Philippine
Amusement and Gaming Corporation [PAGCOR] v.
Aumentado, Jr., 625 SCRA 241 [2010]) Likewise, the
validity of a quitclaim is a question of fact. The Supreme
Court does not hear it since it is not a trier of facts.
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