GR 148235; (August, 2005) (Digest)
G.R. No. 148235 . August 11, 2005
ROSALINA TAGLE, Petitioner, vs. COURT OF APPEALS, FAST INTERNATIONAL CORPORATION and/or KUO TUNG YU HUANG, Respondents.
FACTS
Wilfredo Tagle, husband of petitioner Rosalina Tagle, was recruited by respondent Fast International Corporation (FIC) to work as a fisherman in Taiwan. During his employment contract, the fishing vessel he was on sank after a collision, and he was presumed dead. His widow filed a claim for death benefits with FIC. The claim was approved, and the local insurer issued a check for ₱650,000.00 to the petitioner. Upon receipt, she executed a Release, Waiver and Quitclaim discharging the insurer “and all other persons having interest therein” from all claims.
Subsequently, petitioner filed a complaint before the NLRC for an additional NT$300,000.00 in “labor insurance,” invoking a clause in the employment contract stating that “Additional Labor Insurance shall be provided to the FISHERMAN by the EMPLOYER with a limit of NT$300,000.00 per person… for accident insurance.” The Labor Arbiter dismissed the complaint based on the quitclaim. The NLRC affirmed, holding the insurance proceeds received were in satisfaction of the contractual obligation for accident insurance, and the quitclaim barred further action.
ISSUE
Whether the Release, Waiver and Quitclaim executed by petitioner bars her from claiming the additional NT$300,000.00 accident insurance benefit under the employment contract.
RULING
Yes, the quitclaim is valid and bars the subsequent claim. The Court emphasized that the terms of the employment contract are clear and must be given their literal meaning. Article II, Section 10 of the contract treats compensation for death and accident insurance separately. However, the provision for “Additional Labor Insurance” with a limit of NT$300,000.00 is for “accident insurance covering fishermen.” The death of Wilfredo Tagle, which resulted from an accident (the vessel collision), is a risk covered by such accident insurance. Therefore, the ₱650,000.00 insurance proceeds paid to the petitioner—an amount more than double the NT$300,000.00 limit—constituted the fulfillment of that specific contractual stipulation.
The Release, Waiver and Quitclaim is a valid contract. It expressly released not only the insurance company but also “all other persons having interest therein,” which unequivocally includes the recruitment agency, FIC, as the policyholder. By accepting the substantial insurance payment and executing the quitclaim, petitioner is forever barred from claiming any additional benefits arising from the same incident—her husband’s death. To allow a separate claim for accident insurance after receiving death benefits from an accident would violate the clear terms of the employment contract and render the quitclaim nugatory.