4/29/2020
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In their position paper,[14] Poseidon and Van Doorn argued that the respondents had no
cause of action to collect the remaining 50% of their unpaid wages. To Poseidon and
Van Doorn, the respondents’ voluntary and knowing agreement to the settlement pay,
which they confirmed when they signed the waivers and quitclaims, now effectively
bars their claim. Poseidon and Van Doorn submitted before the LA the signed letter of
acceptance, the waiver and quitclaim, and the cash vouchers to support their stance.
In a Decision[15] dated May 2006, the LA dismissed the respondents’ complaint for lack
of merit, declaring as valid and binding their waivers and quitclaims. The LA explained
that while quitclaims executed by employees are generally frowned upon and do not
bar them from recovering the full measure of what is legally due, excepted from this
rule are the waivers knowingly and voluntarily agreed to by the employees, such as the
waivers assailed by the respondents. Citing jurisprudence, the LA added that the
courts should respect, as the law between the parties, those legitimate waivers and
quitclaims that represent voluntary and reasonable settlement of employees’ claims. In
the respondents’ case, this pronouncement holds more weight, as they understood fully
well the contents of their waivers and knew the consequences of their acts.
The LA did not give probative weight to the May 25, 2005 agreement considering that
the entities which contracted the respondents’ services -Poseidon and Van Doorn — did
not actively participate. Moreover, the LA noted that the respondents’ signed letter of
acceptance superseded this agreement. The LA likewise considered the respondents’
belated filing of the complaint as a mere afterthought.
Finally, the LA dismissed the issue of illegal dismissal, noting that the respondents
already abandoned this issue in their pleadings. The respondents appealed[16] the LA’s
decision before the NLRC.
The Ruling of the NLRC
By Resolution[17] dated December 29, 2006, the NLRC affirmed in toto the LA’s
decision. As the LA did, the NLRC ruled that the respondents’ knowing and voluntary
acquiescence to the settlement and their acceptance of the payments made bind them
and effectively bar their claims. The NLRC also regarded the amounts the respondents
received as settlement pay to be reasonable; despite the cessation of the fishing
operations, the respondents were still paid their full wages from December 2004 to
January 2005 and 50% of their wages from February 2005 until their repatriation in
May 2005.
On
February
12,
2007,
the
NLRC
denied[18]
the
respondents’
motion
for
reconsideration,[19] prompting them to file with the CA a petition for certiorari[20]
under Rule 65 of the Rules of Court.
The Ruling of the CA
In its September 30, 2008 Decision,[21] the CA granted the respondents’ petition and
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