Compromise, settlement recognized means to settle, to end labor disputes

The Labor Code recognizes the conclusiveness of compromises as a means to settle and end labor disputes. Article 227 provides that "(a)ny compromise settlement, including those involving labor standard laws, voluntarily agreed upon by the parties with the assistance of the Bureau or the regional office of the Department of Labor, shall be final and binding, upon the parties. The National Labor Relations Commission or any court shall not assume jurisdiction over issues involved therein except in case of non-compliance thereof or if there is prima facie evidence that the settlement was obtained through fraud, misrepresentation or coercion." In Olaybar vs. NLRC, this Court had occasion, in a labor dispute, to apply the rule that compromises and settlements have the effect and conclusiveness of res judicata upon the parties. [G.R. No. 108556. November 19, 1996]