In that Receipt and Release Homicillada supposedly acknowledged receipt of the amount of P15,750.00 in complete and final settlement of (his) wages, bonuses, overtime pay, leave pay, allotments and all other entitlements as well as sickness wages, reimbursement of medical expenses, medicines and other benefits due (him) x x x accruing from (his) services and employment on the vessel MV Bulk Rhine x x x x and that (he) hereby declare(s) and confirm(s) that (he) (has) no other claims against said vessel, Master, Owners, Operators and Agents and (he) hereby discharge(s) and release(s) them from any other liability whatsoever x x x x"xi[11]Contrary to the finding of the NLRC, petitioners maintain that they attached this quitclaim to their position paper with motion to dismiss which was received by the POEA on 10 April 1995.xii[12] Whether the quitclaim was actually filed and formed part of the records which the POEA and the NLRC decided to ignore, as petitioners would want to impress on us, is largely a question of fact which we choose not to dwell on in this special civil action for certiorari. Besides, as aptly observed by the NLRC: Further, granting the existence of the said quitclaim, it cannot effectively free the respondents from liability as the fact remains that complainant was not afforded the proper medical treatment per physicians advice, it appearing from the records that the respondents only approved the procedure for a pelvic traction on the complaint which was not however the recommended recourse, the Medical Evaluation Certificate dated May 4, 1994 showing that the complainant was advised to undergo laminectomy and dissection of his disc herniation. This is further buttressed by the fact that, even after the complainant was administered with a pelvic traction, the medical certificate dated June 23, 1994 indicated no improvement in the herniation and that the complainant will just the same suffer from a partial permanent disability in the absence of the previously advised surgery. If at all, the only visible help extended by the respondents was diagnostic in nature which answers to the cost of CT-Scan of complainants lumbo-sacral area in the amount of Three Thousand Eight Hundered Pesos (P3,800.00). Certainly this is not an amount to justify a waiver of the claim to which the complainants entitlement has been upheld.xiii[13] Indeed, it is appalling that Homicillada would settle for a measly consideration of P15,570.00, which is grossly inadequate, that it could not have given rise to a valid waiver on the part of the disadvantaged employee. In American Home Assurance Co. v. NLRCxiv[14] this Court held: The law does not consider as valid any agreement to receive less compensation than what a worker is entitled to recover nor prevent him from demanding benefits to which he is entitled. Quitclaims executed by the employees are thus commonly frowned upon as contrary to public policy and ineffective to bar claims for the full measure of the workers legal rights, considering the economic disadvantage of the employee and the inevitable pressure upon him by financial necessity. Thus it is never enough to assert that the parties have voluntarily entered into such a quitclaim. There are other requisites, to wit: (a) That there was no fraud or deceit on the part of any of the parties; (b) That the consideration of the quitclaim is credible and reasonable; and, (c) That the contract is not contrary to law, public order, public policy, morals or good customs or prejudicial

Select target paragraph3