6/7/2020
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considering the economic disadvantage of the employee and the inevitable
pressure upon him by financial necessity. (Citation omitted)
Respondents could have simply paid the judgment award without attaching conditions
that have far-reaching consequences other than those intended by a simple compliance
with what was required under the circumstances - that is, the mandatory execution
proceedings following a favorable judgment allowed under the Labor Code. But they did
not; they had to find a way to tie petitioner's hands permanently, dangling the check as
bait, so to speak. To borrow from a fairly recent ruling of the Court, "[t]he execution [of
the documents] cannot be tolerated as it amounts to a deceptive scheme to
unconditionally absolve employers from every liability.[32]
x x x. As a rule, quitclaims and waivers or releases are looked upon with
disfavor and frowned upon as contrary to public policy. They are thus
ineffective to bar claims for the full measure of a worker's legal rights,
particularly when the following conditions are applicable: 1) where there is
clear proof that the waiver was wangled from an unsuspecting or gullible
person, or (2) where the terms of settlement are unconscionable on their
face. To determine whether the Quitclaims signed by respondents are valid,
one important factor that must be taken into account is the
consideration accepted by respondents; the amount must constitute
a reasonable settlement equivalent to the full measure of their legal
rights. In this case, the Quitclaims signed by the respondents do not appear
to have been made for valuable consideration. x x x [33] (Emphasis
supplied)
For what they did, respondents are guilty of bad faith, and should suffer the
consequences of their actions. One is that their payment of petitioner's claim should
properly be treated as a voluntary settlement of his claim in full satisfaction of the
NLRC judgment - which thus rendered the Petition in CA-G.R. SP No. 124685 moot and
academic.
For its part, the CA refused to apply the pronouncement in Career Phils.
Shipmanagement, insinuating that the situation of the parties in said case and in the
present one are different in that, in the instant case, petitioner "still retains the right to
judicial recourse in the event"[34] that the NLRC decision is reversed, while in Career
Phils. Shipmanagement, "the Supreme Court opted to render the action therein moot
and academic due to the fact that part of the condition is a prohibition on the part of
the seafarer to pursue further claims"[35] as stated in the same Conditional Satisfaction
of Judgment, Receipt of Payment and Affidavit which he was made to sign. The
appellate court's position is flawed: petitioner's situation is no different from that of the
seafarer in the Career Phils. Shipmanagement case. The CA's reasoning laid down in its
pronouncement is a mere convenient play on words. Just as in the Career Phils.
Shipmanagement case, petitioner is equally prohibited from pursuing further claims; it
is not simply that petitioner "still retains the right to judicial recourse"; what is of
significance is that he stands to gain nothing in the end, and yet is unduly prevented
from pursuing further claims - all without the benefit of receiving, in return, valuable
consideration or a reasonable settlement equivalent to the full measure of his legal
rights.
elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/62635
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