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designated physicians' fit to work assessment. Thus, the CA and the NLRC did not
commit any error in their respective decisions and resolutions.
The Deed of Release and
Quitclaim
was
validly
executed; De Vera is not
entitled to attorney's fees.
De Vera also asserts that the NLRC and the CA erred when they ruled that he already
admitted the correctness of the company-designated physicians' medical assessment
when he signed the Deed of Release and Quitclaim on April 22, 2013. He argues that
the respondents committed fraud when they prepared the pro forma quitclaim.
The Court is not persuaded.
While De Vera is correct in stating that quitclaims are frowned upon for being contrary
to public policy, the Court has, likewise, recognized legitimate waivers that represent a
voluntary and reasonable settlement of a worker's claim which should be respected as
the law between the parties. Where the person making the waiver has done so
voluntarily, with a full understanding thereof, and the consideration for the quitclaim is
credible and reasonable, the transaction must be recognized as being a valid and
binding undertaking.[50] Thus, to be valid, a deed of release, waiver, and quitclaim
must meet the following requirements: (1) that there was no fraud or deceit on the
part of any of the parties; (2) that the consideration for the quitclaim is sufficient and
reasonable; and (3) that 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.
[51]
From the foregoing, the Court opines that the subject Deed of Release and Quitclaim is
valid. The fact that the respondents prepared the deed beforehand and merely awaited
De Vera's signature does not automatically prove the commission of fraud. After all,
there was no showing that he was unduly compelled or forced to affix his signature
thereon. Further, the amount of P40,808.16 as consideration for the quitclaim is
reasonable since he is not entitled to any disability benefit and further considering that
he already received from the respondents the amounts of P26,537.20 and P21,614.96,
or a total of P48,152.16, as sickness allowance and maintenance pay. Necessarily, the
deed is not contrary to law, public order, public policy, morals or good customs.
As the subject deed of release and quitclaim is valid, the NLRC and the CA are correct
when they declared that De Vera, by executing the Deed of Release and Quitclaim,
impliedly admitted the correctness of the assessment of the company-designated
physicians and admitted that he could no longer claim for disability benefits.[52]
Finally, since De Vera is not entitled to any of his claims, it goes without saying that he
is also not entitled to attorney's fees. There is no more need to belabour on this point.
WHEREFORE, the petition is DENIED. The August 20, 2015 Decision and the February
5, 2016 Resolution of the Court of Appeals in CA-G.R. SP No. 135608 are hereby
AFFIRMED.
SO ORDERED.
https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/65369
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