GR 105606; (March, 1995) (Digest)
G.R. No. 105606 March 16, 1995
EUGENIA CREDO MERCER, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, HON. QUINTIN C. MENDOZA, NATIONAL SERVICE CORPORATION, OSCAR B. SADUESTE, OSCAR C. VILLASEÑOR, NILDA G. RAMOS, and GERARDO H. SANTOS, respondents.
FACTS
Petitioner Eugenia Credo Mercer filed a complaint for unfair labor practice, underpayment, and damages against the respondents. This case relates to the implementation of a prior Supreme Court decision (G.R. Nos. 69870 and 70295) which ordered her reinstatement to her former position as Chief, Property and Records Section, or to a substantially equivalent position, with three years backwages and damages. If reinstatement was not possible, the Court ordered payment of separation pay. In May 1989, respondents implemented the decision by appointing petitioner to the position of Lady Attendant and paying her P115,428.12 as embodied in a Quitclaim and Release. Petitioner claimed this implementation was in bad faith and a circumvention of the decision, as the Lady Attendant position was much lower in category and involved tasks like cleaning comfort rooms, unlike her former supervisory role. The Labor Arbiter dismissed her complaint, finding respondents had complied, and the NLRC affirmed the dismissal.
ISSUE
Whether the respondents substantially complied with the Supreme Court’s reinstatement order in G.R. Nos. 69870 and 70295 by appointing petitioner as a Lady Attendant and having her sign a Quitclaim and Release.
RULING
The Supreme Court dismissed the petition for lack of merit. It held that private respondents had substantially complied with the Court’s prior decision. The record showed that after receiving the decision, the company informed petitioner that her old position had been abolished due to a reorganization and there were no substantially equivalent vacancies. During a conference before Labor Arbiter Mendoza, petitioner pleaded for reinstatement, initially as a Lady Guard, and then manifested willingness to accept the position of Lady Attendant. The parties reached a compromise on May 8, 1989, where petitioner agreed to assume the position of Lady Attendant with a basic salary equivalent to her previous salary and to receive the monetary settlement. She voluntarily signed the Quitclaim and Release on May 11, 1989. The Court ruled that, under Article 227 of the Labor Code, a voluntarily agreed compromise settlement is final and binding. Citing precedent, a quitclaim amounts to a valid compromise agreement in the absence of coercion, trickery, or unconscionable consideration. There was no proof petitioner was forced to accept the position or sign the quitclaim; evidence indicated it was her choice to have a regular income. Therefore, she was bound by the conditions of the Quitclaim and Release.