Almirante: Waivers and quitclaims

RESPONDENTS were former employees of petitioner Goodrich Manufacturing Corp. assigned as machine operators for its different sections. Sometime in the later part of 2004, on account of lingering financial constraint. Goodrich gave all its employees the option to resign.

Several employees, including respondents, decided to avail themselves of the voluntary resignation option. On Dec. 29, 2004 they were paid their separation pay and on Jan. 3, 2005, they executed their respective waivers and quitclaims.

The following day, Jan. 4, 2005, respondents filed complaints against Goodrich for illegal dismissal with prayer for payment of their full monetary benefits. Did their complaints prosper?

Ruling: No.

First, the contents of the quitclaim documents that have been signed by the respondents are simple, clear and unequivocal.

The records of the case are bereft of any substantial evidence to show that respondents did not know that they were relinquishing their right, short of what they had expected to receive and contrary to what they have so declared.

Put differently, at the time they were signing their quitclaims, respondents honestly believed that the amounts received by them were fair and reasonable settlements of the amounts which they would have received had they refused to voluntarily resign from the company.

Second, respondents claim they were deceived because petitioners did not really terminate their business since Mr. Chua Goy had set up another company in the same line of business as Goodrich.

Such contention, however, was not proven during the hearing before the labor arbiter and the National Labor Relations Commission (NLRC). Hence, such claim is based only on respondents’ surmises and speculations which, unfortunately, can never be used as a valid and legal ground to repudiate their quitclaims.

And third, the considerations received by the respondents from Goodrich do not appear to be grossly inadequate vis-à-vis what they should receive in full. As correctly pointed out by the NLRC, the total awards computed by the Labor Arbiter will definitely even be lesser after deducting 13th month pay for the years 2002 and 2003, which have already been received by the computation.

The difference between the amounts expected from those that were received may, therefore, be considered as a fair and reasonable bargain on the part of both parties (Goodrich Manufacturing Corp. & Nilo Chua Goy vs. Emerlina Ativo, et., al., G.R. No. 188002, Feb. 1, 2010.)

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