Mercer v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioner Eugenia Credo Mercer filed a complaint against respondents National Service Corporation (NSC) and its officers for unfair labor practice, underpayment, and claim for damages, stemming from the implementation of a Supreme Court decision in G.R. Nos. 69870 and 70295. The said decision ordered NSC to reinstate Mercer to her former position or a substantially equivalent one, with backwages, moral damages, and attorney's fees, or separation pay if reinstatement was impossible. Procedural History: NSC implemented the decision by appointing Mercer as Lady Attendant and paying her P115,428.12, as evidenced by a Quitclaim and Release dated May 11, 1989. Mercer alleged that this implementation was done in bad faith and circumvented the Supreme Court's decision. The Labor Arbiter dismissed the case, finding that NSC had complied with the Court's order. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision. The Petition: Petitioner filed a petition for review on certiorari, alleging that NSC failed to comply with the reinstatement order by appointing her to a lower position (Lady Attendant) instead of her former position (Chief, Property and Records Section) or a substantially equivalent one. She claimed the Lady Attendant position involved menial tasks like cleaning comfort rooms and collecting garbage, and that she signed the Quitclaim and Release out of necessity and the incentive of payment.
Issue(s)
Whether private respondents complied with the Supreme Court's order for reinstatement. Whether the Quitclaim and Release signed by the petitioner is valid and binding.
Ruling
The petition is dismissed for lack of merit. The Supreme Court found that private respondents had substantially complied with its decision. The Quitclaim and Release signed by the petitioner was deemed a valid and binding compromise agreement.
Ratio Decidendi
On the issue of compliance with the reinstatement order: The Court found that NSC had substantially complied with the decision. The company informed petitioner that her former position had been abolished due to reorganization, and no substantially equivalent positions were vacant. Two new positions of equivalent rank, Records Custodian and Property Custodian, were occupied, and the only remaining vacancy was Management Analyst, for which petitioner lacked qualifications. During a conference, NSC manifested its intent to pay separation pay. However, petitioner pleaded to be reinstated as Lady Guard, and later, as Lady Attendant, due to her need for a regular monthly income. The parties eventually reached a compromise during a conference before the Labor Arbiter, wherein NSC agreed to hire petitioner as Lady Attendant with a salary equivalent to her previous basic salary, and petitioner signed a Quitclaim and Release in exchange for P115,428.12. On the validity of the Quitclaim and Release: The Court held that Article 227 of the Labor Code provides that any compromise settlement voluntarily agreed upon with the assistance of the Bureau of Labor Relations or the regional office of the DOLE is final and binding. Citing jurisprudence, the Court stated that a quitclaim executed in favor of a company amounts to a valid and binding compromise agreement. In the absence of any showing that petitioner was coerced or tricked into signing the Quitclaim and Release, or that the consideration was very low, she is bound by its conditions. The evidence showed that it was petitioner who requested the position of Lady Attendant to secure a regular income, and she was assured of a salary equivalent to her previous one. Therefore, private respondents substantially complied with the Supreme Court's decision.
Main Doctrine
A quitclaim and release, voluntarily agreed upon with the assistance of the Bureau of Labor Relations or the regional office of the DOLE, is final and binding upon the parties. In the absence of proof of coercion or trickery, or a grossly inadequate consideration, an employee is bound by the conditions of a quitclaim and release.