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Case digest · Quitclaims and compromise agreements
Periquet vs. National Labor Relations Commission
She won her illegal dismissal case, settled, signed quitclaims, and later wanted the full award. Could she take it back?
Facts
The case
Corazon Periquet, a toll collector, won an illegal dismissal case.
The compromise
Instead of returning to work, she accepted a ₱14,000 compromise and gave up reinstatement.
Rehired
She was later rehired as a xerox machine operator and signed a second Quitclaim and Release for ₱9,544. She even sent the company’s corporate legal counsel a memo expressing her gratitude for the additional amount.
1989
On March 11, 1989, almost nine years later, she moved to execute the old judgment. The labor arbiter ordered payment of ₱205,207.42, but the NLRC set aside the order.
Issue
Was Periquet bound by her compromise and quitclaim, or could she still collect the full award under the earlier judgment?
Ruling
She was bound. The Court upheld the compromise and the quitclaim and denied her petition.
Not all waivers and quitclaims are invalid as against public policy. A quitclaim entered into voluntarily, with full understanding, for a credible and reasonable consideration, is binding and cannot be disowned simply because of a change of mind. The law steps in only where there is clear proof that the waiver was obtained from an unsuspecting or gullible person, or where the terms are unconscionable on their face. Her motion was also filed beyond the five-year period.
“Not all waivers and quitclaims are invalid as against public policy. If the agreement was voluntarily entered into and represents a reasonable settlement, it is binding on the parties and may not later be disowned simply because of a change of mind.”
Doctrine
“But where it is shown that the person making the waiver did so voluntarily, with full understanding of what he was doing, and the consideration for the quitclaim is credible and reasonable, the transaction must be recognized as a valid and binding undertaking.”
Bar tip
Test a quitclaim on three points: it was signed voluntarily, the worker understood it, and the amount is credible and reasonable. If all three are present, a change of mind is not a ground to set it aside.
Watch it explained
Pumirma Ka Na sa Quitclaim? May Habol Ka Pa Ba?
This digest is general legal information for education, not legal advice, and it is not a substitute for reading the decision. Quoted passages are taken word for word from the full text.