JCA Security Services, Inc. v. National Labor Relations Commission Sixth Division

G.R. No. 247669 (Notice)

This is a civil case decided by the Philippine Supreme Court's Second Division in its August 24, 2020 resolution in G.R. No. 247669. The legal issue in this case is the validity and enforceability of a quitclaim and release agreement entered into by the parties to settle a labor dispute. The Supreme Court ruled that the quitclaim and release agreement is valid and binding, and that the petitioner's motion to withdraw the petition and terminate the case is proper. The Court noted that quitclaims partake the nature of a compromise, and compromise agreements may be entered into notwithstanding the earlier resolution of the Court denying the petition. The Court further held that the withdrawal of the petition and consequent termination of the case is proper, and the case is hereby closed and terminated.

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SECOND DIVISION

[G.R. No. 247669. August 24, 2020.]

JCA SECURITY SERVICES, INC., petitioner,vs. NATIONAL LABOR RELATIONS COMMISSION SIXTH DIVISION AND JUAN FULGAR GABANZO, respondents.

NOTICE

Sirs/Mesdames :

Please take notice that the Court, Second Division, issued a Resolution dated24 August 2020which reads as follows:

"G.R. 247669 (JCA Security Services, Inc., v. National Labor Relations Commission Sixth Division and Juan Fulgar Gabanzo). — The Quitclaim and Release (Full Satisfaction of Judgment Award) 1 dated September 24, 2019 executed by petitioner and private respondent reads:

That for and in consideration of the sum of TWO HUNDRED TWENTY THOUSAND PESOS (P220,000.00) to me/us paid by JCA SECURITY SERVICES, INC./JUDY M. ABALOS, in settlement of my/our claims as full satisfaction of judgment award, receipt of which is hereby acknowledged to my/our complete and satisfaction of judgment, I/We hereby release and discharge the said respondents and its officer(s) from any/all claims that may be due me/us in connection with my past employment with said establishment and its officers. 2

It has been held that quitclaims are contracts in the nature of a compromise where parties make concessions, a lawful device to avoid litigation. 3 Further, a waiver or quitclaim is a valid and binding agreement between the parties, provided that it constitutes a credible and reasonable settlement, and that the one accomplishing it has done so voluntarily and with a full understanding of its import. 4

A review of the quitclaim and release in the present case shows that it has been validly executed in accordance with the foregoing requirements. Apart from providing a reasonable settlement, the document is signed by Labor Arbiter Marita V. Padolina, private respondent, a lawyer from Public Attorney's Office, and a representative of petitioner.

Considering that Quitclaims partake the nature of a compromise, compromise agreements may be entered into notwithstanding the earlier Resolution of the Court denying the petition. 5 Thus, the withdrawal of the petition and consequent termination of the case is proper.

WHEREFORE, the Court resolves as follows:

(1) GRANT petitioner's Motion [To Consider the Petition for Review on Certiorari Withdrawn and/or Case Closed and Terminated] dated September 25, 2019;

(2) GRANT petitioner's Motion for Reconsideration dated December 4, 2019;

(3) NOTE petitioner's Compliance dated February 17, 2020;

(4) GRANT respondent's Motion for Extension of Time to File Comment;

(5) NOTE respondent's Manifestation (in lieu of Comment); and

(6) DEEM the case CLOSED and TERMINATED.

SO ORDERED." (BALTAZAR-PADILLA, J., on official leave.)

By authority of the Court:

(SGD.) TERESITA AQUINO TUAZONDeputy Division Clerk of Court

 

Footnotes

1.Rollo, pp. 323-325.

2.Id. at 323.

3.Pilipinas Shell Foundation, Inc. v. Fredeluces, 785 Phil. 409, 442 (2016).

4.Plastimer Industrial Corp. vs. Gopo, 658 Phil. 627, 635 (2011), citing Alabang Country Club, Inc. v. NLRC, 503 Phil. 937 (2005).

5. See Jesalva v. Hon. Bautista and Premiere Productions, Inc., 105 Phil. 348-353 (1959); Magbanua v. Uy, 497 Phil, 511, 521 (2005), citing Palanca v. Court of Industrial Relations, 50-C Phil. 354 (1972).

 

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