GR 85393; (September, 1991) (Digest)
G.R. No. 85393 September 5, 1991
ALBA PATIO DE MAKATI, ANASTACIO ALBA and CLAUDIO OLABARRIETA, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, ALBA PATIO DE MAKATI EMPLOYEES ASSOCIATION, HERMOGENES CAGANO, LUCIO CAGANO, RUPERTO CRUZ and BONIFACIO ACLADO, respondents.
FACTS
The Court of Industrial Relations (CIR) found petitioners guilty of unfair labor practice and ordered the reinstatement with back wages of four employees. This decision was affirmed by the Supreme Court in 1984. During execution proceedings before the NLRC, one employee, Lucio Cagano, presented a “Satisfaction of Judgment, Release and Quitclaim” stating that all complainants had received P54,000.00 as full settlement. He claimed authority via special powers of attorney from his co-employees. Based on this document, the Labor Arbiter considered the case closed. Subsequently, two other employees, Bonifacio Aclado and Ruperto Cruz, moved for execution, denying they authorized Lucio Cagano or received any payment. The NLRC then set aside the Labor Arbiter’s order, declaring the quitclaim void and ordering full implementation of the original judgment.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in annulling the Satisfaction of Judgment and ordering the full execution of the final and executory decision.
RULING
The Supreme Court upheld the NLRC’s order. The legal logic is anchored on the invalidity of the quitclaim and the duty to enforce final judgments. The special power of attorney executed for a deceased employee was patently void, as an agency is extinguished by death. For the other employees, the quitclaim, which drastically reduced the computed back wages from over P196,000 to only P54,000, was contrary to public policy. The Court emphasized that quitclaims executed by employees for a consideration far less than the amount adjudged are normally frowned upon as they compromise workers’ rights. The Labor Arbiter erred in approving the document without scrutiny, especially when the counsel of record for some employees was absent. A final judgment of the Supreme Court cannot be rendered meaningless by such an inequitable settlement. The NLRC correctly acted to prevent a denial of justice, as the case had been pending for nearly eighteen years. The petitioners, having submitted to the NLRC’s jurisdiction, cannot repudiate it upon receiving an unfavorable ruling. The temporary restraining order was lifted and the petition dismissed.