G.R. No. 255368 - Abad vs. San Roque Metals, Inc.

Thirty-five (35) employees filed complaints for illegal dismissal against Prudential Customs Brokerage Services, Inc. (PCBSI) and San Roque Metals, Inc. (SRMI).
Executive Labor Arbiter (ELA) Nicodemus G. Palangan, in a Decision dated April 30, 2012, ruled that PCBSI and SRMI illegally dismissed the employees and ordered them to pay backwages and separation pay in lieu of reinstatement.
PCBSI and SRMI appealed to the National Labor Relations Commission (NLRC), which reversed the ELA in a Resolution dated December 28, 2012. NLRC held that only PCBSI employed the workers and ordered PCBSI to reinstate them without backwages but with retained seniority.
The employees moved for reconsideration which the NLRC denied on April 11, 2013.
Employees then filed a Petition for Certiorari with the Court of Appeals (CA).

CA found grave abuse of discretion by the NLRC and reinstated the ELA ruling on July 27, 2015.
PCBSI and SRMI moved for reconsideration which the CA denied.
They filed separate Petitions for Review on Certiorari to the Supreme Court, which the Court denied in a March 2, 2016 Resolution.
The Court affirmed the ELA ruling holding PCBSI and SRMI solidarily liable for illegal dismissal and entitling employees to backwages and separation pay.

Twelve employees (the petitioners) entered into compromise agreements with PCBSI and SRMI following finality of the judgment.
Each compromise agreement stipulated that the settlement amount and employment with SRMI constituted full and final satisfaction of their labor complaints.
The compromise agreements included a quitclaim by the employees releasing additional claims against PCBSI, SRMI, their stockholders, officers, and successors-in-interest.
The parties submitted the compromise agreements before the ELA during a pre-execution conference.

ELA ruled the compromise amounts were not full payments but advances on monetary awards due.
The ELA reaffirmed SRMI’s solidary liability with PCBSI as resolved in the final judgment.
ELA computed total monetary award to petitioners amounting to PHP 20,160,503.00 and issued writ of execution.

SRMI challenged the ELA Order, claiming the compromise agreements barred further claims and questioned SRMI's solidary liability.
SRMI contended its liability should not exceed October 15, 2011, when its contract with PCBSI ceased.

Lack of full understanding by employees as to the agreements’ import.
ELA’s handwritten note created ambiguity affecting consent.
Settlement amounts were unconscionably low (5.20% to 23.42% of monetary awards).

NLRC affirmed SRMI’s solidary liability and rejected late evidence on contract termination.
SRMI’s motion for reconsideration was denied on March 9, 2018.

CA partly granted SRMI’s petition, deleting backwages and separation pay awards on ground compromise agreements validly constituted full payment.
CA rejected NLRC’s findings of ambiguity and unconscionability, emphasizing voluntary signing by petitioners.
CA imposed legal interest on monetary awards.
Petitioners’ motion for partial reconsideration was denied by CA on December 22, 2020.

Petitioners argued that the compromise agreements were not fully understood, thus not valid.
SRMI insisted compromise agreements bar further claims and monetary awards paid were full satisfaction.

Whether the Court of Appeals erred in finding grave abuse of discretion in the NLRC's denial of SRMI's Petition for Extraordinary Remedies.
Whether the compromise agreements executed by the petitioners constitute full, final, and valid satisfaction of their claims against SRMI and PCBSI.
Whether SRMI's solidary liability for backwages and separation pay remains despite the compromise agreements.
Whether the monetary settlement amounts in the compromise agreements were reasonable and whether consent was vitiated due to ambiguity from the ELA’s note.