GR 110261; (August, 1994) (Digest)
G.R. No. 110261 . August 4, 1994. REY PABLO D. SICANGCO, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION AND METRO DRUG, INC., respondents.
FACTS
Petitioner Rey Pablo D. Sicangco was employed by Metro Drug, Inc. (MDI) as Assistant Vice-President for Legal Affairs. In June 1989, MDI informed Sicangco that his position was declared redundant, effective July 2, 1989, and offered separation benefits. Sicangco did not protest but instead negotiated for and received enhanced benefits, including the write-off of a substantial car loan. He subsequently tendered his resignation and, upon receipt of the benefits, signed a “Release, Waiver and Quitclaim” document, which he helped prepare and whose contents were explained to him by another company lawyer.
In February 1990, Sicangco filed a complaint for illegal dismissal and unfair labor practice, claiming his redundancy was a pretext due to his union activities and that he signed the quitclaim out of “dire necessity” caused by illness and financial distress. The Labor Arbiter ruled in his favor, but the National Labor Relations Commission (NLRC) reversed the decision, holding that Sicangco voluntarily resigned and validly executed the quitclaim.
ISSUE
Whether the NLRC committed grave abuse of discretion in ruling that Sicangco voluntarily resigned and executed a valid quitclaim, thereby barring his illegal dismissal claim.
RULING
The Supreme Court dismissed the petition and affirmed the NLRC decision. The legal logic centers on the validity of the quitclaim and the absence of vitiated consent. The Court applied Articles 1335, 1337, and 1338 of the Civil Code on intimidation, undue influence, and fraud. It found no evidence that Sicangco was coerced into resigning or signing the waiver. As a lawyer specializing in labor relations, he was presumed to know his rights and the consequences of his actions. His negotiation for higher benefits demonstrated a voluntary and informed settlement.
The Court cited Periquet v. NLRC, which holds that quitclaims are valid if voluntarily entered into and represent a reasonable settlement. Sicangco’s plea of “dire necessity” was insufficient to annul the release, as it was not shown that the consideration was unconscionable or that he was tricked. The terms were credible and substantial. The NLRC’s factual finding that the termination resulted from a voluntary resignation, not redundancy or illegal dismissal, was supported by evidence and thus not tainted with grave abuse of discretion. The contract was binding, and Sicangco could not later disown it.