‘All other claims of [respondent] are hereby dismissed for lack of merit.
‘SO ORDERED.’
"When [petitioners] filed their joint appeal, docketed as NLRC NCR CA No. 012650-97, [the NLRC] in a Decision, dated May 30, 1997, reversed the
aforecited decision and dismissed the [respondent’s] complaint for lack of merit. [Respondent’s] motion for reconsideration was denied in a Resolution,
dated July 10, 1997."5
Ruling of the Court of Appeals
The Court of Appeals ruled that despite the absence of a written categorical objection to the sufficiency of the payment received as consideration for
the execution of the quitclaim,
jurisprudence supported the right of respondent to demand what was rightfully his under our labor laws. Hence, he should have been allowed to
recover the difference between the amount he had actually received and the amount he should have received.
The CA also found that the NLRC had erroneously applied RA 8042 to the case. The appellate court held that respondent was entitled to the salaries
corresponding to the unexpired portion of his Contract, in addition to what he had already received.
Hence, this Petition.6
The Issues
Petitioners raise the following issues for this Court’s consideration:
"A. Whether or not the Honorable Court of Appeals committed reversible error when it took cognizance of an issue of fact which was raised for the first
time on appeal.
"B. Whether or not the Honorable Court of Appeals committed reversible error in its 27 July 2001 Decision and 29 January 2002 Resolution by
affirming the 27 February 1997 Decision of the Labor Arbiter which rendered as null and void and without binding effect the release and quitclaim
executed by the respondent in favor of the petitioners, and, thereafter, granted the respondent monetary award." 7
In the main, the issue is whether respondent, despite having executed a quitclaim, is entitled to a grant of his additional monetary claims.
The Court’s Ruling
The Petition has no merit.
At the outset, the Court notes the Manifestation of the Office of the Solicitor General (OSG), recommending that "the decision dated May 30, 1997 of
the NLRC be annulled and set aside and that [Respondent] Esquillo be awarded the total amount of his salaries corresponding to the unexpired portion
of his contract of employment."8
Main Issue:
Entitlements of a Dismissed
Employee Who Has Executed a Quitclaim
The factual findings of labor officials, who are deemed to have acquired expertise in matters within their respective jurisdictions, are generally accorded
not only respect but finality.9 In the present case, the labor arbiter found respondent’s dismissal to be illegal and devoid of any just or authorized cause.
The factual findings of the NLRC and the CA on this matter were not contradictory. Hence, the Court finds no reason to deviate from theirfactual finding
that respondent was dismissed without any legal cause.
Indeed, an employee cannot be dismissed except for cause, as provided by law, and only after due notice and hearing. 10 Employees who are
dismissed without cause have the right to be reinstated without loss of seniority rights and other privileges; and to be paid full back wages, inclusive of
allowances and other benefits, plus proven damages.
With regard to contract workers, in cases arising before the effectivity of RA 8042 (the Migrant Workers and Overseas Filipinos Act11), it is settled that if
"the contract is for a fixed term and the employee is dismissed without just cause, he is entitled to the payment of his salaries corresponding to the
unexpired portion of his contract." 12In the present case, the Contract of respondent was until July 26, 1995. Since his dismissal from service effective
December 18, 1994, was not for a just cause, he is entitled to be paid his salary corresponding to the unexpired portion of his Contract, in the total
amount of US$9,447.
We now go to the Release and Quitclaim signed by respondent. The document, which was prepared by Petitioner ABV Rock Group, 13 states: