When are quitclaims valid? - G.R. No. 182331

G.R. No. 182331

"x x x.

In the absence of proof that any of the vices of consent are present, the petitioners’ acceptance letters and quitclaims are valid; thus, barring them from claiming additional separation pay.

            The Court now comes to the issue on the validity of the acceptance letters and quitclaims that the petitioners executed, which they claim do not preclude them from asking for the benefits rightfully due them under the law.

          It is true that quitclaims executed by employees are often frowned upon as contrary to public policy.[34] Hence, deeds of release or quitclaims cannot bar employees from demanding benefits to which they are legally entitled or from contesting the legality of their dismissal. The acceptance of those benefits would not amount to estoppel.[35]

          However, the Court, in other cases, has upheld quitclaims if found to comply with the following requisites: (1) the employee executes a deed of quitclaim voluntarily; (2) there is no fraud or deceit on the part of any of the parties; (3) the consideration of the quitclaim is credible and reasonable; and (4) the contract is not contrary to law, public order, public policy, morals or good customs or prejudicial to a third person with a right recognized by law.[36]

          In this case, there is no allegation of fraud or deceit employed by the
respondents in making the petitioners sign the acceptance letters and quitclaims. Neither was there any claim of force or duress exerted upon the petitioners to compel them to sign the acceptance letters and quitclaims. Likewise, the consideration is credible and reasonable since the petitioners are getting more than the amount required under the law. Thus, the acceptance letters and quitclaims executed by the petitioners are valid and binding.

Considering that the petitioners have already waived their right to file an action for any of their claims in relation to their employment with Globalbank, the question of whether Metrobank can be held liable for these claims is now academic. However, in order to put to rest any doubt in the petitioners’ minds as to Metrobank’s liabilities, we shall proceed to discuss this issue.         

x x x."