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employment medical examination on Castillon is not one of the bases of this Court on
the finding of work-relatedness. However, in this case, it is only suggestive that his
colon cancer was not yet symptomatic, not having been detected at the time he was
examined.
Thus, Castillon's illness is work-related and compensable. Under Section 20(B)(1),
respondents must pay petitioners US$50,000.00 and an additional amount of
US$7,000.00 to each child under 21 years, but not exceeding four (4) children.[111]
Respondents must also pay petitioners an amount of US$1,000.00 for the burial
expenses.[112]
III
Generally, the law frowns upon quitclaims executed by employees for being contrary to
public policy. However, when it is executed voluntarily, fully understanding its terms
and with a corresponding reasonable consideration, the quitclaim is valid and binding.
[113]
Legitimate waivers or quitclaims are regarded as the law between the employers and
employees. In Radio Mindanao Network, Inc. v. Amurao III,[114]
Indeed, there are legitimate waivers that represent the voluntary and
reasonable settlements of laborers' claims that should be respected by the
Court as the law between the parties. Where the party has voluntarily made
the waiver, with a full understanding of its terms as well as its
consequences, and the consideration for the quitclaim is credible and
reasonable, the transaction must be recognized as a valid and binding
undertaking, and may not later be disowned simply because of a change of
mind. A waiver is essentially contractual.[115]
When the waiver or quitclaim is freely and voluntarily executed, it discharges the
employer from liability to the employee.[116] If the agreement was voluntarily entered
into and represents a reasonable settlement, it is binding on the parties and may not
later be disowned on a whim.[117]
In Goodrich Manufacturing Corporation v. Ativo:[118]
It is true that the law looks with disfavor on quitclaims and releases by
employees who have been inveigled or pressured into signing them by
unscrupulous employers seeking to evade their legal responsibilities and
frustrate just claims of employees. In certain cases, however, the Court has
given effect to quitclaims executed by employees if the employer is able to
prove the following requisites, to wit: (1) the employee executes a deed of
quitclaim voluntarily; (2) there is no fraud or deceit on the part of any of the
parties; (3) the consideration of the quitclaim is credible and reasonable;
and (4) 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.[119]
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