G.R. No. 193484; January 18, 2012
Hypte R. Aujero, Petitioner, vs. Philippine Communications Satellite Corporation, Respondent.

FACTS

Petitioner Hypte R. Aujero started working for respondent Philippine Communications Satellite Corporation (Philcomsat) in 1967. On August 15, 2001, after 34 years of service, he applied for early retirement, which was approved effective September 15, 2001. At the time, he was Senior Vice-President with a monthly salary of ₱274,805.00 and was entitled to retirement benefits at a rate of one and a half of his monthly salary for every year of service. On September 12, 2001, he executed a Deed of Release and Quitclaim in favor of Philcomsat after receiving a check for ₱9,439,327.91. Almost three years later, he filed a complaint for unpaid retirement benefits, claiming the actual amount due was ₱14,015,055.00. He argued the quitclaim was void as the amount he received was unconscionable, and he only accepted it because he was in dire need and would not receive any payment otherwise. He cited a company Retirement Plan created in 1977 and a Trust Agreement with United Coconut Planters Bank (UCPB) in 1997, which stated the trust fund was for the exclusive benefit of employees and that Philcomsat had waived all rights to its contributions. He also pointed to an August 15, 2001 letter from Philcomsat’s Chairman to UCPB instructing the release of ₱9,439,327.91 to him and ₱4,575,727.09 to Philcomsat, which he claimed showed a pre-conceived plan to deprive him of part of his benefits. The Labor Arbiter ruled in his favor, finding the quitclaim unconscionable and ordering Philcomsat to pay the balance of ₱4,575,727.09 plus salary for August 15 to September 15, 2001. The National Labor Relations Commission (NLRC) reversed the Labor Arbiter, upholding the quitclaim as valid and dismissing the complaint, noting the petitioner’s education and high position negated claims of duress and his three-year delay in filing the complaint. The Court of Appeals affirmed the NLRC’s decision.

ISSUE

Whether the Deed of Release and Quitclaim executed by the petitioner is valid and constitutes a bar to his claim for unpaid retirement benefits.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ decision. The quitclaim is valid and binding. The Court held that quitclaims are not necessarily void, especially when the consideration is credible and reasonable, and the execution is voluntary. The petitioner, a well-educated Senior Vice-President and licensed accountant, failed to prove that his consent was vitiated by fraud, deceit, or duress. His claim of dire need was insufficient to invalidate the quitclaim, as he did not immediately assert any defect and waited almost three years to file his complaint. The amount he received, ₱9.4 million, was substantial and not unconscionable. The Court also found that the Retirement Plan and Trust Agreement did not automatically entitle him to the full computed amount, as the actual benefits could be subject to other lawful deductions or agreements. The letter instructing the release of funds to both the petitioner and Philcomsat did not by itself prove bad faith or an illegal scheme. Therefore, having voluntarily accepted the payment and executed the quitclaim, the petitioner is barred from claiming additional retirement benefits.