SC voids quitclaims for deceit
SC ruled in favor of the employees, finding that the quitclaims they signed were void for being executed by CORPS with an intent to defraud
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SC ruled in favor of the employees, finding that the quitclaims they signed were void for being executed by CORPS with an intent to defraud
A set of quitclaims was nullified by the Supreme Court (SC) after finding that the employer tricked its employees into signing them.
In a decision penned by Associate Justice Antonio T. Kho Jr., dated 3 April and uploaded 5 June 2024, the Supreme Court’s Second Division found that Corporate Protection Services Phils. Inc. (CORPS) constructively dismissed Domingo Naldo Jr. et al.
The Court ordered CORPS to reinstate the employees and pay them backwages and other benefits.
The employees were hired by CORPS as security guards and despite reporting for 12 hours a day every day, including regular and special holidays, they did not receive regular or special holiday pay, as well as rest day pay, service incentive leave pay, 13th month pay, and emergency cost of living allowance.
Their conciliation-mediation conference before the National Conciliation Mediation Board to discuss their grievances, a representative of CORPS offered to pay all their money claims if the employees submitted signed resignation letters.
The employees relied on this and complied wherein CORPS also made them sign separate quitclaims. Afterward, CORPS gave them checks but covering only the amounts of trust fund savings and cash bonds.
The employees tried to return the checks, but CORPS explained that the checks for the remaining money claims, which were still being processed, would follow.
When the employees showed up for work the next day, their supervisors prevented them, claiming they had already supposedly resigned.
But by the end of the month, CORPS still had not given them checks for the remaining money claims, and they were not allowed to report for duty.
A complaint was filed by the employees CORPS for nonpayment of salary and benefits and constructive illegal dismissal.
The complaint was dismissed by the Labor Arbiter, ruling that the employees voluntarily signed the quitclaims and the resignation letters and are thus barred from seeking further claims against CORPS.
Both the National Labor Relations Commission and the Court of Appeals ruled that the quitclaims and resignation letters were invalid.
However, the SC ruled in favor of the employees, finding that the quitclaims they signed were void for being executed by CORPS with an intent to defraud.
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