Agoy vs NLRC : 112096 : January 30, 1996 : J Francisco : Third Division 1 of 6 http://sc.judiciary.gov.ph/jurisprudence/1996/jan1996/112096.htm THIRD DIVISION [G.R. No. 112096. January 30, 1996] MARCELINO B. AGOY, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, EUREKA PERSONNEL MANAGEMENT SERVICES, INC., ET. AL., respondents. SYLLABUS 1. REMEDIAL LAW; EVIDENCE; FINDINGS OF FACT OF ADMINISTRATIVE BODIES; RULE; EXCEPTION. - This Court has consistently adhered to the rule that in reviewing administrative decisions such as those rendered by the NLRC, the findings of fact made therein are to be accorded not only great weight and respect, but even finality, for as long as they are supported by substantial evidence. It is not the function of the Court to once again review and weigh the conflicting evidence, determine the credibility of the witnesses or otherwise substitute its own judgment for that of the administrative agency on the sufficiency of the evidence. Nevertheless, when the inference made or the conclusion drawn on the basis of certain state of facts is manifestly mistaken, the Court is not estopped from exercising its power of review. 2. LABOR AND SOCIAL LEGISLATION; TERMINATION OF EMPLOYMENT; PROBATIONARY EMPLOYEES; ENTITLED TO SECURITY OF TENURE; GROUNDS FOR TERMINATION. - Probationary employees, notwithstanding their limited tenure, are also entitled to security of tenure. Thus, except for just cause as provided by law or under the employment contract, a probationary employee cannot be terminated. As explicitly provided under Article 281 of the Labor Code, a probationary employee may be terminated on two grounds: (a) for just cause or (b) when he fails to qualify as a regular employee in accordance with reasonable standards made known by the employer to the employee at the time of his engagement. 3. ID.; ID.; ID.; EMPLOYERS OBLIGATION TO INFORM THE PROBATIONARY EMPLOYEE REGARDING THE STANDARDS OR REQUIREMENTS THAT MUST BE COMPLIED WITH IN ORDER TO BECOME A REGULAR EMPLOYEE; NOT COMPLIED WITH IN CASE AT BAR. - The record is bereft of any evidence to show that respondent employer ever conveyed to petitioner-employee the standards or requirements that he must comply with in order to become a regular employee. In fact, petitioner has consistently denied that he was even given the chance to qualify for the position for which he was contracted. Private respondent Al-Khodaris general averments regarding petitioners failure to meet its standards for regular employment, which were not even corroborated by any other evidence, are insufficient to justify petitioners dismissal. 4. ID.; ID.; QUITCLAIMS, WAIVERS OR RELEASES; DISFAVORED. - In our jurisprudence, quitclaims, waivers or releases are looked upon with disfavor, particularly those executed by employees who are inveigled or pressured into signing them by unscrupulous employers seeking to evade their legal responsibilities. The fact that petitioner signed his notice of termination and failed to make any outright objection thereto did not altogether mean voluntariness on his part. Neither did the execution of a final settlement and receipt of the amounts agreed upon foreclose his right to pursue a legitimate claim for illegal dismissal. Expounding on the reasons therefor, the following pronouncements are in point: In labor jurisprudence, it is well established that quitclaims and/or complete releases executed by the 1/20/2016 8:48 PM

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