4/20/2021 E-Library - Information At Your Fingertips: Printer Friendly Not all quitclaims are per se invalid or against public policy, except: (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 faces; in these cases, the law will step in to annul the questionable transactions.[35] However, to allow the recovery of full disability or death benefits by virtue of an invalid quitclaim presupposes that there is a legal entitlement to such benefits in full. Concomitantly, it is settled that no person should unjustly enrich himself or herself at the expense of another.[36] Unjust enrichment exists "when a person unjustly retains a benefit from the loss of another, or when a person retains money or property of another against the fundamental principles of justice, equity and good conscience."[37] As such, it must be shown that a party was unjustly enriched in the sense that the term unjustly could mean illegally or unlawfully.[38] In this case, the respondents (especially Magsaysay) cannot be considered to have taken advantage of Castillon in the signing of the quitclaim as there was no clear proof that the latter was gullible or was defrauded. Moreover, the terms of the settlement, especially as to the amount of compensation cannot be considered as unconscionable. This is because Castillon cannot be considered as being entitled to death benefits in the first place for failure of his heirs to substantiate the existence of work-relatedness, a requirement for compensability. Courts, as well as magistrates presiding over them, are not omniscient; they can only act on the facts and issues presented before them in appropriate pleadings.[39] As such, evidence is needed to establish an approximate amount of monetary claim in the first place before one can conclude that the amount being offered by the employer in a given quitclaim is conscionable or unconscionable. Since no such monetary claim was established/proven with substantial evidence of work-relatedness, it reasonably follows that any sum provided in the succeeding quitclaim can never amount to anything unconscionable. Relatedly, since the evidence on record hardly establishes any relationship between Castillon's colon cancer and his stay onboard M/V Amethyst Ace, it would be manifestly unjust to require Magsaysay to part with its funds in order to pay off an obligation which it never had. While the undersigned greatly sympathizes with the plight of Castillon's heirs, he cannot in good conscience concede to the fact that one party will be unduly benefited at the expense of another. Conclusion All told, the available records do not establish through substantial evidence that Castillon's colon cancer developed due to or was caused by his work as a seafarer onboard M/V Amethyst Ace. Castillon's short stint of six (6) months as a seafarer onboard the subject vessel, coupled with an unsubstantiated allegation of poor dietary provisions, are not enough to lead the mind of a reasonable person to accept that such facts are adequate to justify the conclusion that such colon cancer was work-related. Moreover, an interpretative rule in settling doubts such as social justice cannot https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66406 32/35