4/29/2020
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Generally, this Court looks with disfavor at quitclaims executed by employees for being
contrary to public policy.[44] Where the person making the waiver, however, has done
so voluntarily, with a full understanding of its terms and with the payment of
credible and reasonable consideration, we have no option but to recognize the
transaction to be valid and binding.[45]
We find the requisites for the validity of the respondents’ quitclaim present in this
case. We base this conclusion on the following observations:
First, the respondents acknowledged in their various pleadings, as well as in the very
document denominated as "waiver and quitclaim," that they voluntarily signed the
document after receiving the agreed settlement pay.
Second, the settlement pay is reasonable under the circumstances, especially when
contrasted with the amounts to which they were respectively entitled to receive as
termination pay pursuant to Section 23 of the POEA-SEC and Article 283 of the Labor
Code. The comparison of these amounts is tabulated below:
Settlement Pay
Termination Pay
Joel S.
Fernandez
US$3134.33
US$1120.00
Artemio A. Booc
US$2342.37
US$800.00
Felipe S. Saurin,
Jr.
US$2639.37
US$800.00
Tito R. Tamala
US$2593.79
US$280.00
Thus, the respondents undeniably received more than what they were entitled to
receive under the law as a result of the cessation of the fishing operations.
Third, the contents of the waiver and quitclaim are clear, unequivocal and
uncomplicated so that the respondents could fully understand the import of what they
were signing and of its consequences.[46] Nothing in the records shows that what they
received was different from what they signed for.
Fourth, the respondents are mature and intelligent individuals, with college degrees,
and are far from the naive and unlettered individuals they portrayed themselves to be.
Fifth, while the respondents contend that they were coerced and unduly influenced in
their decision to accept the settlement pay and to sign the waivers and quitclaims, the
records of the case do not support this claim. The respondents’ claims that they were
in "dire need for cash" and that they would not be paid anything if they would not sign
do not constitute the coercion nor qualify as the undue influence contemplated by law
sufficient to invalidate a waiver and quitclaim,[47] particularly in the circumstances
attendant in this case. The records show that the respondents, along with their other
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