G.R. No. 182331 ; April 18, 2012
MA. CORINA C. JIAO, ET AL., Petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, GLOBAL BUSINESS BANK, INC., ET AL., Respondents.

FACTS

The petitioners were regular employees of Philippine Banking Corporation (Philbank), each with over ten years of service. Philbank had a Gratuity Pay Plan providing a benefit of one month’s salary per year of service, up to a maximum of 24 months, payable upon retirement, resignation, or separation due to authorized causes. In February 2000, Philbank merged with Global Business Bank, Inc. (Globalbank), resulting in redundancy for the petitioners’ positions. Globalbank offered a Special Separation Program (SSP) granting a package equivalent to 150% of one month’s salary per year of service. The petitioners availed of the SSP, signed acceptance letters, and executed Release, Waiver, and Quitclaim documents in favor of Globalbank. In August 2002, Metropolitan Bank and Trust Company (Metrobank) acquired Globalbank’s assets and liabilities.
Subsequently, the petitioners filed complaints for non-payment of gratuity pay under the old Philbank plan, arguing that the redundancy separation triggered their entitlement. They contended that the quitclaims they signed were void for being contrary to law, morals, and public policy, as they were executed under economic duress and for a consideration less than what was legally due. The Labor Arbiter dismissed the complaints, a decision affirmed by the NLRC and the Court of Appeals, which held the quitclaims valid and barred the claims.

ISSUE

Whether the Release, Waiver, and Quitclaim executed by the petitioners are valid and constitute a bar to their claim for gratuity pay under the old Philbank plan.

RULING

The Supreme Court denied the petition and upheld the validity of the quitclaims. The legal logic is anchored on the principle that while quitclaims executed by employees are often frowned upon, they are not automatically void. They are binding if the parties entered into them voluntarily, with a full understanding of their terms, and for a reasonable consideration. The Court found these elements present. The petitioners, educated bank employees, voluntarily accepted the more favorable SSP package, which provided 150% of monthly salary per year of service, a rate exceeding the statutory minimum for redundancy under Article 283 of the Labor Code (one month per year). They were not coerced; they had the option to refuse and pursue legal remedies but chose not to. The consideration was ample and credible. Their subsequent claim for additional gratuity pay under the old plan, after knowingly accepting a superior separation package, constituted unjust enrichment. The merger and subsequent asset acquisition by Metrobank did not alter this conclusion, as the quitclaims specifically waived all claims against Globalbank, its successors, and assigns. Therefore, the quitclaims were valid compromises that settled all claims arising from their employment termination.