3/31/2021 E-Library - Information At Your Fingertips: Printer Friendly Labor Attaché within the Philippine Overseas Labor Office premises in Kuwait. Reason and logic would, thus, dictate that there was something patently irregular about the foregoing documents. To allow this supposed settlement - anchored on an inapplicable legal precept - to operate as a bar to [respondent's] legitimate right to institute judicial proceedings in order to advance her welfare would be the height of injustice. x x x [50] The CA adopted the observation of the NLRC on the patent irregularity of the documents presented by petitioners purportedly showing respondent's voluntarily resignation. In addition, the CA held that respondent would not have pursued her suit if she indeed resigned voluntarily from her work abroad.[51] Notably, the LA, the NLRC, and the CA all ruled against the validity, regularity, and due execution of the subject resignation letter, Affidavit of Quitclaim and Desistance, and the final settlement. The Court finds no reason to deviate from their findings. In any case, within the context of a termination dispute, the rule is that quitclaims, waivers or releases are looked upon with disfavor and are commonly frowned upon as contrary to public policy and ineffective to bar claims for the measure of a worker's legal rights.[52] The reason for this rule is that the employer and the employee do not stand on the same footing, such that quitclaims usually take the form of contracts of adherence, not of choice.[53] At this juncture, it bears to emphasize that findings of fact of administrative agencies and quasi-judicial bodies, which have acquired expertise because their jurisdiction is confined to specific matters, are generally accorded not only great respect but even finality.[54] Unless there is a showing of grave abuse of discretion or where it is clearly shown that the factual findings were reached arbitrarily or in utter disregard of the evidence on record, they are binding upon the Court.[55] In this case, the Court finds no such showing of arbitrariness or grave abuse of discretion on the part of the LA and the NLRC. On the contrary, the finding that respondent was constructively dismissed is amply supported by the evidence on record. In cases of constructive dismissal, the impossibility, unreasonableness, or unlikelihood of continued employment leaves an employee with no other viable recourse but to terminate his or her employment.[56] "An employee is considered to be constructively dismissed from service if an act of clear discrimination, insensibility or disdain by an employer has become so unbea[r]able to the employee as to leave him or her with no option but to forego his or her continued employment."[57] From this definition, it can be inferred that various situations, whereby the employer intentionally places the employee in a situation which will result in the latter's being coerced into severing his ties with the former, can result in constructive dismissal.[58] In SHS Perforated Materials, Inc., et al. v. Diaz,[59] the employee was forced to resign and submit his resignation letter because his salary was unlawfully withheld by the employer. This Court ruled that the unlawful withholding of salary amounts to constructive dismissal.[60] https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/65972 6/12