be impugned by mere self-serving allegations.27 Proof of an irregularity in its execution is absolutely essential. The Agreement likewise bears the signature of Conciliator-Mediator Diaz. Thus, the signatures of these officials sufficiently prove that Iladan was duly assisted when she signed the waiver and settlement. Concededly, the presumption of regularity of official acts may be rebutted by affirmative evidence of irregularity or failure to perform a duty. In this case, no such evidence was presented. Besides, "[t]he Court has ruled that a waiver or quitclaim is a valid and binding agreement between the parties, provided that it constitutes a credible and reasonable settlement, and that the one accomplishing it has done so voluntarily and with a full understanding of its import."29 Absent any extant and clear proof of the alleged coercion and threats Iladan allegedly received from respondents that led her to terminate her employment relations with respondents, it can be concluded that Iladan resigned voluntarily.” Thus, in order to overcome the presumption of regularity in the performance of official business for the purpose of nullifying a compromise agreement executed during SEnA before the POLO, the OFW has to prove irregularity in the SEADO’s performance of his/her duties or that the settlement agreement is contrary to law, morals, public order and public policy. (d) OFWs have the right to adequate legal counsel/assistance but have no access to competent and independent legal counsel/assistance of their choice during the SEnA conferences before the POLOs. While the SEnA Rules discourage the participation of lawyers in the SEnA conference itself, it does not bar OFWs from seeking legal advice or assistance. In order to address the lack of legal advice/assistance of OFWs during the SEnA conferences before the POLOs, it is recommended that a program or policy be instituted in order to provide the OFW access to virtual or online legal advice/assistance through the services of the Public Attorney’s Office, the Integrated Bar of the Philippines, legal aid clinics, pro-bono lawyers or through the OFW’s counsel of choice. V. Recommendations A. Recognizing that addressing the challenges of institutional capacity to absorb an expanding caseload for the long term will require reforms in the judicial architecture, meantime at the interim, the following procedural enhancements could be proposed to improve administrative efficiency in the judiciary and thus compel duty bearers to act with more expediency and public accountability: 1. Recording of the date the case was submitted for decision/resolution should be specifically stated in the decisions of the Labor Arbiter, the NLRC, the Court of Appeals and the Supreme Court. With this information, it can be determined if there was a substantial delay at each level, either before, or after the case has been submitted for decision. 2. Strictly implement at each level a monitoring system on the status of each case in order to determine if the last pleading has already been filed, and whether or not the case should already be submitted for resolution. In many cases, even if the last pleading has 65

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