6/7/2020
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execution proceedings, and wanted to prevent garnishment of their accounts; that
petitioner's illness was not contracted during his employment with them; that diabetes
is not a compensable occupational disease; that petitioner's failure to submit to a postemployment medical test by a company-designated physician foreclosed his right to
claim disability benefits; and that for the foregoing reasons, petitioner is not entitled to
his other claims.
Our Ruling
The Court grants the Petition.
Respondents profess that the Conditional Satisfaction of Judgment, Receipt of Payment,
and Affidavit which petitioner was made to sign were prepared in good faith and simply
to comply with the execution proceedings below and prevent garnishment of their
accounts. However, this Court believes otherwise. Hidden behind these documents
appears to be a convenient ploy to deprive petitioner of all his rights to claim indemnity
from respondents under all possible causes of action and in all available fora, and
effectively for nothing in return or exchange - because in the event that the NLRC
ruling is reversed, then petitioner must return what he received, thus leaving him with
the proverbial empty bag. This is fundamentally unfair, and goes against public policy.
As was held before, human life is not more expendable than corporate capital.[24] The
survival of the petitioner and his family depends on the former's ability to find and
perform work for wages they need to secure food, shelter, clothing, and the education
of his children. It may be that in this jurisdiction, petitioner may ultimately be adjudged
as not entitled to the monetary claims he seeks, but in other fora - such as in Panama,
Japan, or any other country - he may be found to be entitled thereto, and to other
indemnities as well. Yet by affixing his signature upon the Conditional Satisfaction of
Judgment, Receipt of Payment, and Affidavit, petitioner effectively surrendered all his
rights and waived all his claims and causes of action in all jurisdictions, and in
exchange for nothing. Indeed, in the Affidavit, petitioner even went so far as to certify
and warrant that he will not file any other complaint or prosecute any suit or action
here or in any other country after receiving the settlement amount.
6. That I have no further claims whatsoever in any theory of law against the
Owners of MV "NIKOMARIN" because of the payment made to me. That I
certify and warrant that I will not file any complaint or prosecute any suit or
action in the Philippines, Panama, Japan or any other country against the
shipowners and/or the released parties herein after receiving the payment of
US$66,000.00 or its peso equivalent x x x.[25] (Emphasis in the original)
This waiver by petitioner in exchange for nothing has in fact become a reality, since the
CA reversed the NLRC ruling, which means that petitioner would now have to return
what he received from the respondents, and yet he is left with no available recourse
since he agreed that he will not "prosecute any suit or action in the Philippines x x x
against the shipowners and/or the released parties herein after receiving the payment
of US$66,000.00 or its peso equivalent."[26] "Any suit or action" literally includes a
petition before this Court to review the CA reversal - or the instant petition. It also
covers a claim for interest that may justly accrue in his favor during the
pendency of the case.
elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/62635
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