G.R. No. 167813 ; June 27, 2006
BENJAMIN L. SAROCAM, Petitioner, vs. INTERORIENT MARITIME ENT., INC., and DEMACO UNITED LTD., Respondents.

FACTS

Petitioner Benjamin Sarocam was hired as a bosun under a 12-month contract. While on board, he suffered a lumbar sprain from a fall. He was repatriated and examined by the company-designated physician, Dr. Teodoro Pidlaoan, on December 5, 2000. After follow-up, he was declared “fit for duty” on December 13, 2000. On March 20, 2001, petitioner executed a release and quitclaim, acknowledging receipt of US$405.00 as sick wages and releasing his employers from further liability. However, on November 27, 2001, he filed a complaint for disability benefits, presenting medical certificates from three personal physicians dated July-August 2001, which recommended disability gradings under the POEA schedule.
The Labor Arbiter dismissed the complaint, citing the “fit for duty” declaration and the valid quitclaim. The NLRC affirmed but modified, awarding petitioner three months’ salary for the unexpired contract under RA 8042. The Court of Appeals dismissed Sarocam’s petition, ruling the issues were factual and that he was estopped by his quitclaim.

ISSUE

Whether the Court of Appeals erred in: (1) upholding the company-designated physician’s “fit for duty” declaration over the contrary findings of petitioner’s personal physicians; and (2) ruling that the executed quitclaim estopped petitioner from claiming disability benefits.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals. On the first issue, the Court emphasized that factual findings of quasi-judicial agencies, when supported by substantial evidence, are accorded respect and finality. The company physician’s assessment was based on examinations conducted shortly after repatriation, with normal test results and no back pain complaints by December 13, 2000. In contrast, petitioner’s medical certificates were issued seven to eight months later, without proof that the conditions assessed were directly connected to the work-related injury or existed at the time of the “fit for duty” declaration. The POEA contract designates the company physician for assessment, and petitioner failed to substantiate any bias or error in that assessment.
On the second issue, the Court upheld the quitclaim as valid. Not all quitclaims are invalid; they are binding if voluntarily executed with a reasonable settlement. The quitclaim was handwritten by petitioner, who acknowledged receiving US$405.00 as full settlement. There was no evidence of fraud, deceit, or unconscionable terms. His acceptance of the payment without protest, coupled with the timely “fit for duty” finding, reinforced the quitclaim’s validity. The constitutional protection of labor does not sanction unjust enrichment or the repudiation of a voluntary and reasonable settlement.