Case Name HYPTE R. AUJERO, petitioner , vs.
PHILIPPINE
COMMUNICATIONS SATELLITE CORPORATION, respondent.
GR No. | Date G.R. No. 193484. January 18, 2012.
Topic Waiver of Rights
Parties involved HYPTE R. AUJERO, petitioner, vs. PHILIPPINE
COMMUNICATIONS SATELLITE CORPORATION, respondent.
Ponente Reyes J
General Summary 1967: Aujero once worked as an accountant and Senior Vice President for Philippine
Communications Satellite Corp (PhilComSat) and after 34 years, applied for early retirement.
His retirement was approved that entitled him to retirement benefits amounting to 1 ½ of his
salary for every year of service. To this, he signed a Deed of Release and Quitclaim, to which
he received P9, 439,327.91 in cheque.
3 years after, the petitioner filed a complaint for unpaid retirement benefits,
claiming that the actual amount of his retirement pay is P14,015,055.00 and what he received
was unreasonable, praying to declare his quitclaim as null and void. According to the petitioner,
he had no choice but to accept a lesser amount as he was in dire need.
Facts
1. August 15, 2001: Early retirement of the Aujerto (resigned employee-Petitioner) from Philcompsant (employer
respondent). He is entitled to receive to one and a half of his monthly salary for every year of service.
2. September 12, 2001: Petitioner executed a Deed of Release and Quitclaim in Respondent’s favor following
the receipt of the latter of P9,439,327.91.
3. After 3 years: Petitioner filed a complaint for unpaid retirement benefits, claiming that the actual amount of his
retirement pay is P14,015,055 and the P9,439,327.91 he received is unconscionable. According to him he had
no choice but to accept a lesser amount since he is in dire need. and he signed the quitclaim despite the
considerable deficiency as no single centavo would be released to him if he did not execute a release and waiver
in Philcomsat's favor.
4. Labor Arbiter’s Decision: Issued a decision in petitioner’s favor directing Philcomsat to pay him the amount
of P4,575,727.09 and P274,805.00, representing the balance of his retirement benefits and salary for the period
from August 15 to September 15, 2001, respectively.
5. National Labor Relations Commission (NLRC)’s decision: GRANTED Philcomsat's appeal and reversed and
set aside LA Lustria's May 31, 2006 Decision.
6. The CA further ruled that the NLRC was correct in upholding the validity of the petitioner's quitclaim.
Issue/s
Whether the quitclaim executed by the petitioner in Philcomsat's favor is valid, thereby foreclosing his
right to institute any claim against Philcomsat.
Ruling
● Yes. Petition is denied.
Reasoning
1. Absent any evidence that any of the vices of consent is present and considering the petitioner's position
and education, the quitclaim executed by the petitioner constitutes a valid and binding agreement.
2. Not all waivers and quitclaims are invalid as against public policy. If the agreement was voluntarily entered into
and represents a reasonable settlement, it is binding on the parties and may not later be disowned simply
because of a change of mind. It is only where there is clear proof that the waiver was wangled from an
unsuspecting or gullible person, or the terms of settlement are unconscionable on its face, that the law will step
in to annul questionable transaction.
3. Where it is shown that the person making the waiver did so voluntarily, with full understanding of what he was
doing, and the consideration for the quitclaim is credible and reasonable, the transaction must be recognized as
a valid and binding undertaking. (Goodrich Manufacturing Corporation v. Ativo)
4. That the petitioner was all set to return to his hometown and was in dire need of money would likewise not
qualify as undue pressure sufficient to invalidate the quitclaim. "Dire necessity" may be an acceptable ground to
annul quitclaims if the consideration is unconscionably low and the employee was tricked into accepting it, but is
not an acceptable ground for annulling the release when it is not shown that the employee has been forced
“(note that no force was exerted by the respondent it was voluntarily signed by the petitioner)” to execute it.
On Labor Arbiter’s Decision : it hard to believe that the petitioner would voluntarily waive a significant
portion of his retirement pay. He found the consideration supporting the subject quitclaim unconscionable
and ruled that the respondent failed to substantiate its claim that the amount received by the petitioner
was a product of negotiations between the parties.
On National Labor Relations Commission (NLRC)’s decision: The petitioner failed to allege, much less, adduce evidence
that Philcomsat employed means to vitiate his consent to the quitclaim. The petitioner is well educated, a licensed
accountant and was Philcomsat's Senior Vice-President prior to his retirement; he cannot therefore claim that he signed
the quitclaim without understanding the consequences and implications thereof.
“It should be stressed that complainant-appellee even waited for a period of almost three (3)
years before he filed the complaint. If he really felt aggrieved by the amount he received,
prudence dictates that he immediately would call the respondent-appellant's attention and at the
earliest opportune shout his objections, rather than wait for years, before deciding to claim his
supposed benefits, [e]specially that his alleged entitlement is a large sum of money. Thus, it is
evident that the filing of the instant case is a clear case of afterthought, and that complainant
appellee simply had a change of mind. This We cannot allow.”
