Workers Act, or even under his employment contract, for his claim for his unpaid salary for the unexpired portion of his contract.” There were no OFW cases involving claims of land based OFWs for compensation and benefits for work-related injury, illness or death that were decided by the Supreme Court in 2015-2019. Thus, while the two OFW cases herein cited did not reach the Supreme Court, the decision of the Labor Arbiter and the Commission is to deny the claims of OFWs who suffered work-related injuries where there is no allegation or finding of illegal dismissal. What is needed at this point is to review the provisions of R. A. 8042, as amended, as well as the POEA-SEC for land based OFWs in order to provide for joint and solidary liability of the foreign employer and the local recruitment agency for compensation and benefits in case of work-related injury, illness or death of the land based OFW similar to, or comparable to, that of the sea based OFWs. 4.5 Compromise Agreements, Quitclaims and the SEnA Process One way to end a protracted legal dispute is by way of compromise. A compromise agreement is defined as "a contract whereby the parties, by making reciprocal concessions, avoid a litigation or put an end to one already commenced." 95 Once freely and validly entered into, a compromise agreement becomes the judgment on the merits of the case and has the force of law between the parties. Amicable settlements through compromise agreements are a preferred mode of settling labor disputes as these give the parties the opportunity to resolve the labor dispute in the least possible time and in the process, avoid a protracted and costly litigation. Section 10 of R. A. 8042, as amended, requires that "(a)ny compromise/amicable settlement or voluntary agreement on money claims inclusive of damages under this section shall be paid within thirty (30) days from approval of the settlement by the appropriate authority.” NLRC records show that for the period 2015-2017, 60-80% of all labor cases terminated at the Labor Arbiter’s level were ended either through settlement while undergoing the Singe-Entry Approach (SEnA) process or through compulsory arbitration before the Labor Arbiter.96 NLRC data for the period 2010-2019 also show that for OFW cases, except for the year 2010, monetary awards through amicable settlement are much greater than monetary awards secured through judgment on the merits of the case. In 2019, the total monetary awards in favor of the OFW complainants amounted to PhP 3,946,932,081.16. Of this figure, PhP 2,813878,887.15, or 71.29% was awarded by way of amicable settlement while only PhP 1,133,053,194.01 or 28.71% was awarded through judgment on the merits. 95 96 Article 2028, Civil Code of the Philippines NLRC Performance Reports 2015-2017 60