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Arbiter that they have entered into a full and final amicable settlement of
their impending case and of all claims that complainant has on respondents.
... one of the quitclaim documents executed by complainant is in the
vernacular. From that alone, he cannot deny any knowledge and
understanding of the contents thereof. Such was further bolstered by the
Joint Motion to Dismiss filed by him and respondents, attesting to their full
settlement.[19] (Emphasis in the original, citation omitted)
Castillon then filed a motion for reconsideration, but to no avail.[20] Thus, he filed an
appeal before the Court of Appeals, claiming that the proceedings before Labor Arbiter
Del Rosario was a "sham[,]" because it was Magsaysay which caused the filing of the
complaint. Moreover, he argued that he did not voluntarily sign the release document
and the joint motion to dismiss. He further contended that he is entitled to full disability
benefits of US$60,000.00 because his illness is work-related.[21]
The Court of Appeals dismissed the petition, thus:
WHEREFORE, the petition is DENIED. The NLRC's Decision dated October
28, 2011 and Resolution dated December 29, 2011 in NLRC Case No. OFW
VAC-06-000027-201 are AFFIRMED.
SO ORDERED.[22]
The Court of Appeals ruled that the release documents signed by Castillon barred him
from claiming total disability benefits.[23] The appellate court found that the quitclaim
was "knowingly and voluntarily" executed by Castillon, considering the absolute
character of the document.[24] The Affidavit of Claimant executed by Castillon
categorically stated that the US$20,000.00 covered all benefits due to him under the
Philippine Overseas Employment Administration Standard Employment Contract.[25]
Moreover, the Court of Appeals pointed out that the document was translated and was
signed by Castillon in both English and Filipino versions. Castillon also handwrote the
word "RELEASE" and the affirmative responses to the clarificatory questions in the
documents. Castillon cannot assail the validity of the quitclaim on the ground that it
was Magsaysay who filed the complaint before the National Labor Relations Commission
because he fully participated in the proceedings. It is also noteworthy that the quitclaim
was presented to and approved by Labor Arbiter Del Rosario.[26]
Further, the amount of US$20,000.00 is already a fair and reasonable settlement of
Castillon's claim, considering that his illness is not work-related. The Court of Appeals
considered the determination of the company-designated physician, along with
Castillon's family history of intestinal malignancy.[27]
Thus, the Court of Appeals affirmed the National Labor Relations Commission's finding
of res judicata. All elements of res judicata are present in this case: (1) the order of
dismissal was final; (2) it was an adjudication on the merits because it was premised
upon a settlement; (3) Labor Arbiter Del Rosario had jurisdiction over the subject
https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66406
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