Case Digest: Aujero v. Philcomsat

G.R. No. 193484 : January 18, 2012




It was in 1967 that the petitioner started working for respondent Philippine Communications Satellite Corporation (Philcomsat) as an accountant in the latter's Finance Department. After thirty-four (34) years of service, the petitioner applied for early retirement. His application for retirement was approved, entitling him to receive retirement benefits at a rate equivalent to one and a half of his monthly salary for every year of service. At that time, the petitioner was Philcomsat's Senior Vice-President with a monthly salary of Two Hundred Seventy-Four Thousand Eight Hundred Five Pesos (P274,805.00).

Petitioner executed a Deed of Release and Quitclaimin Philcomsats favor.

Almost three (3) years thereafter, the petitioner filed a complaint for unpaid retirement benefits, claiming that the actual amount of his retirement pay is Fourteen Million Fifteen Thousand and Fifty-Five Pesos (P14,015,055.00) and the P9,439,327.91 he received from Philcomsat as supposed settlement for all his claims is unconscionable, which is more than enough reason to declare his quitclaim as null and void.

Labor Arbiter issued a Decisionin the petitioners favor, directing Philcomsat to pay him the amount of P4,575,727.09 and P274,805.00, representing the balance of his retirement benefits and salary for the period from August 15 to September 15, 2001, respectively.

NLRC granted Philcomsats appeal and reversed and set aside LAs Decision. The NLRC dismissed the petitioners complaint for unpaid retirement benefits and salary in consideration of the Deed of Release and Quitclaim he executed following his receipt from Philcomsat of the amount of P9,439,327.91, which constitutes the full settlement of all his claims against Philcomsat.

By way of the assailed Decision, the CA found no merit in the petitioners claims, holding that the NLRC did not act with grave abuse of discretion in giving due course to the respondents appeal. The CA further ruled that the NLRC was correct in upholding the validity of the petitioners quitclaim.

ISSUE: Whether or not the quitclaim executed by the petitioner in Philcomsats favor is valid, thereby foreclosing his right to institute any claim against Philcomsat?

HELD: Court of Appeals decision is sustained.


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.[29]Considering the petitioner's claim of fraud and bad faith against Philcomsat to be unsubstantiated, this Court finds the quitclaim in dispute to be legitimate waiver.

The petitioner's educational background and employment stature render it improbable that he was pressured, intimidated or inveigled into signing the subject quitclaim. This 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 the petitioner 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.