8/26/2020 E-Library - Information At Your Fingertips: Printer Friendly 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 11/14

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