ALFREDO VELOSO and EDITO LIGUATON, vs. DEPARTMENT OF LABOR AND EMPLOYMENT, NOAH'S ARK SUGAR CARRIERS AND WILSON T. GO.
- G.R. Number: G.R. No. 87297
- Promulgated: 1991-08-05
- Ponente: Cruz, J.
Doctrine
The law disfavors quitclaims and releases obtained by inveiglement or pressure, but legitimate voluntary waivers that represent reasonable settlements must be respected.
A waiver or quitclaim is binding if it was voluntarily entered into with full understanding and supported by credible, reasonable consideration; only unconscionable or clearly wangled waivers may be annulled.
Facts
The petitioners claimed they were forced to sign releases in favor of their private employer because of dire necessity; the employer insisted the compromises were freely entered into (petition vs. respondent dispute).
While a motion for reconsideration was pending, petitioner Alfredo Veloso (through his wife) signed a Quitclaim and Release for P25,000; counsel manifested satisfaction of judgment the same day.
Petitioner Liguaton filed a motion to dismiss based on a Release and Quitclaim for P20,000 which he acknowledged receiving from the private respondent.
The petitioners later sought to impugn the releases on 20 September 1988 alleging they signed under 'extreme necessity'; the Undersecretary of Labor rejected this claim.
Issues
Whether the quitclaims and releases executed by the petitioners are invalid for being signed under duress or extreme necessity.
Whether the petitioners may renege on the compromise agreements because they later regretted them or because a motion for recomputation was pending.
Ruling
The petition is dismissed; the Undersecretary's order rejecting the petitioners' claim of coercion is affirmed because the quitclaims were voluntarily and knowingly executed.
The monetary awards to Jeric Dequito, Custodio Ganuhay, Conrado Mori and Rogelio Veloso are deleted for being settled; execution shall proceed as to awards to Alfredo Veloso and Edito Liguaton.
Keywords
G.R. No. 87297, quitclaims and releases, compromise agreement, unfair labor practices, underpayment, non-payment of overtime, non-payment of holiday benefits, motion for reconsideration, Satisfaction of Judgment, Motion to Declare Quitclaim Null and Void, Article 6, New Civil Code, Article 22, New Civil Code, Pampanga Sugar Development Co., Inc. v. Court of Industrial Relations, dire necessity, certiorari, Article 227 Labor Code, fraud, misrepresentation, coercion, motion