disfavor and are largely ineffective to bar claims for the measure of a worker's
legal rights.29[29]
To be valid, a Deed of Release, Waiver and/or 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 credible 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.30
[30] Courts have stepped in to annul questionable transactions, especially where
there is clear proof that a waiver, for instance, was obtained from an unsuspecting
or a gullible person; or where the agreement or settlement was unconscionable on
its face. A quitclaim is ineffective in barring recovery of the full measure of a
worker's rights, and the acceptance of benefits therefrom does not amount to
estoppel. Moreover, a quitclaim in which the consideration is scandalously low and
inequitable cannot be an obstacle to the pursuit of a worker's legitimate claim.31
[31]
Based on the foregoing disquisition, we find the Acknowledgment and
Undertaking to be void, as contrary to public policy. Other than the fact that the
Acknowledgment and Undertaking did not provide for any consideration given in
favor of Lutero, it is likewise evident that the terms thereof are unconscionable and
29[29] Phil. Employ Services and Resources, Inc. v. Paramio, G.R. No. 144786, April 15, 2004,
427 SCRA 732, 755.
30[30] Danzas Intercontinental, Inc. v. Daguman, G.R. No. 154368, April 15, 2005, 456 SCRA
382, 397-398.
31[31]
698, 708.
R & E Transport, Inc. v. Latag, G.R. No. 155214, February 13, 2004, 422 SCRA