Title
Arlo Aluminum, Inc. vs. Pinon, Jr.
Case
G.R. No. 215874
Decision Date
Jul 5, 2017
A gondola accident led to Vic Edward’s death; Vicente sought unpaid wages despite a P150,000 quitclaim. Courts ruled the quitclaim valid, dismissing claims against Arlo Aluminum.
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Case Digest (G.R. No. 215874)

Facts:

Background and Contractual Relationships
Petitioner Arlo Aluminum, Inc. (Arlo Aluminum) is a corporation engaged in the fabrication and supply of aluminum moldings. In 2009, it was contracted by Eton Properties Philippines, Inc. (Eton Properties) to supply and install aluminum and glass glazing works for the Eton Residences Greenbelt condominium project in Makati City. Arlo Aluminum subcontracted this work to E.M. PiAon Glazing (EMP Glazing), one of whose employees was Vic Edward PiAon (Vic Edward), the son of respondent Vicente PiAon, Jr. (Vicente).

The Accident
On January 27, 2011, Vic Edward and ten other EMP Glazing employees were aboard a gondola installing glass and aluminum on the 32nd floor of the Eton Residences Project when it crashed. All eleven employees, including Vic Edward, died in the incident.

Financial Assistance and Quitclaim
Eton Properties and Arlo Aluminum extended financial assistance of P150,000.00 to the families of the victims. Vicente, representing his deceased son, signed a Deed of Release, Waiver, and Quitclaim on February 3, 2011, releasing all claims related to Vic Edward’s death in exchange for the P150,000.00.

Labor Complaint
On May 3, 2011, Vicente filed a complaint on behalf of his deceased son before the Labor Arbiter (LA) for underpayment of wages, unpaid benefits, and other monetary claims. He argued that Vic Edward’s wages were below the minimum wage and that the P150,000.00 was only financial assistance, not a settlement of all claims.

Arlo Aluminum’s Defense
Arlo Aluminum countered that Vic Edward was not its employee but EMP Glazing’s. It also argued that the quitclaim was valid and that the P150,000.00 covered all labor claims.

Labor Arbiter’s Ruling
The LA ruled that Vic Edward was an employee of EMP Glazing, not Arlo Aluminum, but found that EMP Glazing failed to prove it paid Vic Edward his correct wages and benefits. It awarded Vicente P145,276.22 for underpaid wages and unpaid benefits but dismissed claims against Arlo Aluminum and Eton Properties.

NLRC’s Decision
The NLRC modified the LA’s ruling, holding Arlo Aluminum, Eton Properties, and EMP Glazing jointly and severally liable for Vic Edward’s unpaid wages and benefits under Article 106 of the Labor Code.

Court of Appeals’ Decision
The CA affirmed the NLRC’s decision, ruling that the quitclaim was invalid because it was signed under duress and that EMP Glazing was a labor-only contractor. It held Arlo Aluminum, Eton Properties, and EMP Glazing jointly and severally liable.

Issue:

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Ruling:

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Ratio:

  1. Validity of the Quitclaim: For a quitclaim to be valid, it must: (a) be free from fraud or deceit, (b) have sufficient and reasonable consideration, and (c) not be contrary to law or public policy. Here, the P150,000.00 was reasonable and sufficient to cover the P145,276.22 awarded by the LA and affirmed by the NLRC. There was no evidence of fraud or duress in obtaining the quitclaim.

  2. Return or Deduction of Consideration: Even if the quitclaim were invalid, the P150,000.00 should either be returned or deducted from the monetary award. Allowing recovery beyond this amount would result in double compensation.

  3. Jurisdiction Over Other Claims: Claims not arising from the employer-employee relationship, such as those related to the accident, must be pursued in the proper courts, as the LA has no jurisdiction over such matters.

Conclusion:

The Court held that the quitclaim was valid and that Arlo Aluminum had already satisfied its liabilities to Vic Edward. The complaint was dismissed for lack of merit.


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