G.R. No. 93059; June 3, 1991
EDMUNDO SAMANIEGO, ANTONIO L. ACOSTA, JAIME L. DIAZ and PABLO MANAHAN, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, SANDVIK PHILIPPINES, INC., KRISTER BROBECK and AKE FRIBERG, respondents.

FACTS

Petitioners were managerial employees of Sandvik Philippines, Inc. Due to a perceived financial crisis, the company planned a reorganization that would eliminate middle management positions. On August 24, 1987, management presented petitioners with two options: termination with separation pay, or voluntary resignation with more favorable benefits. After initial negotiations failed, talks resumed the next day. The company improved the voluntary resignation package. Three petitioners accepted it immediately; the fourth initially chose termination but later also opted for the improved resignation terms. All signed prepared resignation letters, acknowledged receipt of benefits, and executed quitclaims waiving any legal claims against the company. They received and deposited their checks and, in some cases, accepted transfer of company vehicles.
Subsequently, petitioners sent a letter stating they received the benefits “under protest” and later filed a complaint for illegal dismissal before the NLRC. The Labor Arbiter ruled in their favor, finding the reorganization a pretext for illegal dismissal. The NLRC reversed this decision, holding that the petitioners voluntarily resigned.

ISSUE

Whether the NLRC committed grave abuse of discretion in ruling that the petitioners voluntarily resigned from their employment and were not illegally dismissed.

RULING

The Supreme Court dismissed the petition, upholding the NLRC’s ruling. The legal logic centered on distinguishing between termination and voluntary resignation. The Court found that the petitioners were not dismissed; instead, they freely chose the voluntary resignation option after arm’s-length negotiations that resulted in improved benefits. Their actions subsequent to the agreement—signing resignation letters and quitclaims, accepting and depositing checks, and receiving additional benefits like vehicles—were consistent with a voluntary and binding settlement, not with coercion.
The Court applied the principle that not all quitclaims are invalid. Citing Periquet v. NLRC, it held that a waiver or quitclaim is binding if voluntarily entered into with full understanding and for a reasonable settlement. The petitioners, as educated managerial employees who negotiated for better terms, could not later disown their agreement without clear proof of vitiated consent or unconscionable terms, which were absent. Their act of filing a protest after the fact did not negate the voluntariness of their prior actions. Since there was no showing of grave abuse of discretion by the NLRC, the extraordinary writ of certiorari could not be granted.