Facts:

The case involves the petitioners, Anglo-Eastern Shipping Co. Ltd. and Overseas Global Transport Inc., and the private respondent, Alberta Grecia. The events transpired in June 1977, specifically the formal agreement that took place on June 2, 1977. The matter arose from an employment contract related to Greeks' claim against the petitioners. On May 31, 1977, the parties filed a Compromise Agreement with the court, wherein they indicated their willingness to resolve the dispute amicably. The essence of the agreement stipulated that Philippine law would govern the claim raised by Grecia, as there was no substantial evidence indicating that Hong Kong compensation law applied or that the deceased was covered by the British P&I Club and its stipulations. In exchange for waiving any other potential claims against each other in the case, the private respondent accepted the amount of eighty-five thousand pesos (₱85,000.00) as a ful

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Facts:

Parties and Representations

• The petitioners are Anglo-Eastern Shipping Co. Ltd. and Overseas Global Transport Inc.
• The respondents include the National Seamen Board, the Honorable Secretary of Labor Blas Ople, and Alberta Grecia (the private respondent).
• Counsel for petitioners and respondents are clearly identified, with the private respondent having recently substituted her counsel for purposes of the settlement.

Background and Employment Contract

• The dispute arose under a subject contract of employment.
• The parties agreed that the private respondent’s claim would be governed by Philippine law.
• There was no evidence on record showing that the Hongkong Compensation Law applied or that the deceased had been covered by the British P&I Club or its rules.

Settlement Negotiation and Agreement

• On May 31, 1977, petitioners and the private respondent, assisted by their respective legal counsels, filed a pleading containing a Compromise Agreement.
• The agreement stipulated that the private respondent would accept a payment of eighty-five thousand pesos (P85,000.00) from the petitioners as the full and complete settlement of her claim under Philippine law.
• By accepting the amount, the parties waived any further claims against each other regarding the disputed matter.
• The Compromise Agreement also noted that the initiation of the settlement was by the private respondent, who, after unsuccessful attempts to contact her counsel on record, engaged new counsel without prejudice to her obligations to the former counsel.

Filing and Court Proceedings

• The filing of the Compromise Agreement was duly made on June 2, 1977, with proper representation by both parties.
• Prior resolutions in this case, dated March 16, 1977 and May 17, 1977, were rendered moot by the new settlement arrangement.

Judicial Resolution

• The Court, in its resolution, set aside the previous resolutions and approved the Compromise Agreement as prayed for by the parties.
• The resolution was concurred by multiple Justices—Fernando (Chairman), Barredo, Aquino, Concepcion, Jr., and Santos—indicating a unanimous decision in favor of the approval of the compromise.

Issue:

Validity of the Compromise Agreement

• Whether the settlement agreement, which apportioned an amount of P85,000 as full settlement of claims under Philippine law, is legally valid and binding on the parties.
• Whether the agreement sufficiently waived all further claims between the petitioners and the private respondent.

Jurisdiction and Applicable Law

• Whether Philippine law was the correct applicable law for governing the private respondent’s claim under the employment contract given the absence of evidence for the application of alternative legal regimes (i.e., Hongkong Compensation Law or British P&I Club rules).

Effect of Substitution of Counsel

• Whether the substitution of counsel by the private respondent, done for settlement purposes, affected the legitimacy of the Compromise Agreement.
• Whether such substitution could be made without prejudice to the private respondent’s previous legal obligations.

Setting Aside Prior Resolutions

• Whether it was proper for the Court to set aside previous resolutions (dated March 16, 1977 and May 17, 1977) in light of the newly submitted and mutually agreed compromise.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)