G.R. No. 142001 . July 14, 2005.
MERLINDA MADRIAGA, ET AL., Petitioners, vs. THE HONORABLE COURT OF APPEALS, HON. TITO F. GENILO and PHILIPPINE DAIRY PRODUCTS CORPORATION, Respondents.

FACTS

This case involves a protracted labor dispute concerning the regularization of workers supplied to Philippine Dairy Products Corporation (PDPC) by labor contractors. In a prior Supreme Court Resolution (G.R. No. 85577, 1990), the Court affirmed a Voluntary Arbitrator’s decision declaring a group of workers as regular employees of PDPC. The Court explicitly extended the benefit of regularization to all workers “similarly situated” to the original complainants. The petitioners in the present case are among those “similarly situated” workers.
Subsequently, PDPC entered into a Compromise Agreement with the original complainants, which included a provision for their reinstatement and regularization. The petitioners, claiming they were covered by the prior Supreme Court ruling, filed a motion before the Voluntary Arbitrator to compel PDPC to also regularize them. The Voluntary Arbitrator and the Court of Appeals denied their motion, finding that the petitioners had already executed individual “Receipt, Release and Quitclaim” documents in favor of PDPC, thereby settling their claims.

ISSUE

Whether the petitioners, as workers “similarly situated” to the original complainants, are entitled to regularization despite having executed quitclaim documents.

RULING

The Supreme Court denied the petition and affirmed the rulings of the lower tribunals. The legal logic centers on the finality and binding effect of a compromise agreement and a valid quitclaim. While the Court’s prior ruling established the legal principle that “similarly situated” workers were entitled to regularization, this entitlement is a demandable right that can be waived or settled.
The petitioners failed to overcome the legal presumption of regularity and voluntariness in the execution of the quitclaim documents. They presented only bare, unsubstantiated allegations of vitiated consent, such as fraud or deceit, without providing competent evidence. In the absence of proof that the quitclaims were executed involuntarily or under inequitable circumstances, they remain valid as the law between the parties. Consequently, by accepting monetary consideration and signing the quitclaims, the petitioners effectively relinquished their claim to regularization under the prior judgment. The Court upheld the sanctity of compromise settlements as a means to end litigation, emphasizing that such agreements, once entered into freely and voluntarily, have the force of res judicata.