HYPTE R. AUJERO v. PHILIPPINE COMMUNICATIONS SATELLITE CORPORATION G.R. No. 193484, 18 January 2012, SECOND DIVISION (Perez, J.)

Absent any evidence that any of the vices of consent is present, the quitclaim executed by a party constitutes a valid and binding agreement.

FACTS:

Petitioner Hypte Aujero was the Vice President of respondent company Philippine Communications Satellite Corporation (Philcomsat). After 34 years, he applied for an early retirement which was approved. This entitled Aujero to receive his retirement benefits at a rate equivalent to one and a half of his monthly salary for every year of service.

Aujero subsequently executed a Deed of Release and Quitclaim in Philcomsat’s favor following his receipt from the latter of a check in the amount of P9,439,327.91. After 3 years, Aujero filed a complaint for unpaid retirement benefits claiming that the actual amount of his retirement pay is P14,015,055.00. Aujero contends that the significantly deficient amount he previously received was more than an enough reason to declare his quitclaim null and void. Aujero further claimed that he had no choice but to accept the lesser amount as he was in dire need of money.

The Labor Arbiter (LA) ruled in favor of Aujero and directed Philcomsat to pay the balance of his retirement pay. The LA maintained that Philcomsat failed to substantiate its claim that the amount received by Aujero was a product of negotiations between the parties. On appeal, the National Labor Relations Commissions (NLRC) reversed the decision of the LA and decided in favor of Philcomsat. The Court of Appeals affirmed the decision of the NLRC.

ISSUE:

Whether the quitclaim executed by the petitioner in Philcomsat’s favor is valid, thereby foreclosing his right to institute any claim against Philcomsat

HELD:

Petition GRANTED

While the law looks with disfavor upon releases and quitclaims by employees who are inveigled or pressured into signing them by unscrupulous employers seeking to evade their legal responsibilities, a legitimate waiver representing a voluntary settlement of a laborer's claims should be respected by the courts as the law between the parties. Considering Aujero’s claim of fraud and bad faith against Philcomsat to be unsubstantiated, the Court finds the quitclaim in dispute to be legitimate waiver.

That Aujero was all set to return to his hometown and was in dire need of money would likewise not qualify as undue pressure sufficient to invalidate the quitclaim. Dire necessity may be an acceptable ground to annul quitclaims if the consideration is unconscionably low and the employee was tricked into accepting it, but is not an acceptable ground for annulling the release when it is not shown that the employee has been forced to execute it. While it is

the Court’s duty to prevent the exploitation of employees, it also behooves this Court to protect the sanctity of contracts that do not contravene our laws.

Aujero’s educational background and employment stature render it improbable that he was pressured, intimidated or inveigled into signing the subject quitclaim. The Court cannot permit the petitioner to relieve himself from the consequences of his act, when his knowledge and understanding thereof is expected. Also, the period of time that Aujero allowed to lapse before filing a complaint to recover the supposed deficiency in his retirement pay clouds his motives, leading to the reasonable conclusion that his claim of being aggrieved is a mere afterthought, if not a mere pretention.