Wednesday, April 1, 2015

The quitclaims executed by retrenched employees in favor of petitioners were therefore not voluntarily entered into by them. Their consent was similarly vitiated by mistake or fraud. The law looks with disfavor upon quitclaims and releases by employees pressured into signing by unscrupulous employers minded to evade legal responsibilities.





"x x x.
Padilla’s quitclaim and release does not negate his having been illegally dismissed

It is of no consequence that Padilla ostensibly executed a quitclaim and release in favor of Am-Phil.1âwphi1 This court’s pronouncements in F.F. Marine Corporation v. National Labor Relations Commission,57 which similarly involved an invalid retrenchment, are of note:


Considering that the ground for retrenchment availed of by petitioners was not sufficiently and convincingly established, the retrenchment is hereby declared illegal and of no effect. The quitclaims executed by retrenched employees in favor of petitioners were therefore not voluntarily entered into by them. Their consent was similarly vitiated by mistake or fraud. The law looks with disfavor upon quitclaims and releases by employees pressured into signing by unscrupulous employers minded to evade legal responsibilities. As a rule, deeds of release or quitclaim cannot bar employees from demanding benefits to which they are legally entitled or from contesting the legality of their dismissal. The acceptance of those benefits would not amount to estoppel. The amounts already received by the retrenched employees as consideration for signing the quitclaims should, however, be deducted from their respective monetary awards.58 (Citations omitted)

In sum, the Court of Appeals committed no error in holding that there was no grave abuse of discretion amounting to lack or excess of jurisdiction on the part of the National Labor Relations Commission in affirming the May 9, 2005 decision of Labor Arbiter Eric V. Chuanico holding that respondent Paolo Jesus T. Padilla was illegally dismissed.

x x x."


G.R. No. 188753               October 1, 2014
AM-PHIL FOOD CONCEPTS, INC., Petitioner,
vs. PAOLO JESUS T. PADILLA, Respondent
.