Goodrich Manufacturing Corp. etc vs. Ativo et. al. G.R. 188002, February 1, 2010

Goodrich Manufacturing Corp. etc vs. Ativo et. al.

 G.R. 188002, February 1, 2010

Lina’s group executed the quitclaims absent any coercion from GMC following their voluntary resignation from the company. The contents of the quitclaim documents signed by them are simple, clear and unequivocal. There is no proof to show that they did not know they were relinquishing their right short of what they had expected to receive and contrary to what they have declared. At the time they signed the quitclaims, they honestly believed that the amounts received by them were fair and reasonable settlements of the amounts they would have received had they refused to voluntarily resign from GMC. Indeed the considerations received by Lina’s group do not appear to be grossly inadequate vis a vis what they should receive in full. It even included the 13th month pay for the years 2002 and 2003 which they already received prior to the filing of their complaints.

Can employees who already signed waivers and quitclaims later on still file a complaint for illegal dismissal?

Quitclaims and waivers executed by employees are valid if employer is able to prove that

(1) The employees executed the deed voluntarily;

(2) There is no fraud or deceit on the part of any parties;

(3) The consideration of the quitclaim is credible and reasonable; and

(4) It is not contrary to law, public order, public policy, morals or good customs, or

Prejudicial to third persons with a right recognized by law.

Their claim that they were deceived because GMC did not really terminate its business was not proven and was based only on their surmises and speculations which can never be used as a valid and legal ground to repudiate their quitclaims.