6/7/2020
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In effect, while petitioner[27] had the luxury of having other remedies
available to it such as its petition for certiorari pending before the appellate
court, and an eventual appeal to this Court, respondent,[28] on the other
hand, could no longer pursue other claims, including for interests that may
accrue during the pendency of the case.[29]
That respondents did not invoke the prohibition in the Affidavit - when the instant
Petition was instituted - does not take away the fact that petitioner has been unduly
deprived of such recourse through the documents he was made to sign.
In Career Philippines, believing that the execution of the LA Decision was
imminent after its petition for injunctive relief was denied, the employer filed
before the LA a pleading embodying a conditional satisfaction of judgment
before the CA and, accordingly, paid the employee the monetary award in
the LA decision. In the said pleading, the employer stated that the
conditional satisfaction of the judgment award was without prejudice to its
pending appeal before the CA and that it was being made only to prevent
the imminent execution.
The CA later dismissed the employer's petition for being moot and academic,
noting that the decision of the LA had attained finality with the satisfaction
of the judgment award. This Court affirmed the ruling of the CA, interpreting
the 'conditional settlement' to be tantamount to an amicable settlement of
the case resulting in the mootness of the petition for certiorari, considering
(i) that the employee could no longer pursue other claims, and (ii) that the
employer could not have been compelled to immediately pay because it had
filed an appeal bond to ensure payment to the employee.
Stated differently, the Court ruled against the employer because the
conditional satisfaction of judgment signed by the parties was highly
prejudicial to the employee. The agreement stated that the payment
of the monetary award was without prejudice to the right of the
employer to file a Petition for certiorari and appeal, while the
employee agreed that she would no longer file any complaint or
prosecute any suit of [sic] action against the employer after
receiving the payment.[30] (Emphasis supplied)
Within the context of the constitutional, legislative, and jurisprudential guarantees
afforded to labor, the position petitioner has been led into is unjust, unfair, and
arbitrary.
In More Maritime Agencies, Inc. v. NLRC,[31] the Court ruled that:
The law does not consider as valid any agreement to receive less
compensation than what a worker is entitled to recover nor prevent him
from demanding benefits to which he is entitled. Quitclaims executed by the
employees are thus commonly frowned upon as contrary to public policy and
ineffective to bar claims for the full measure of the workers legal rights,
elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/62635
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