G.R. No. 108713 - Olaybar vs. National Labor Relations Commission

Petitioners were regular employees of Orient Marine and Fishing Resources, Inc.
They were dismissed on the ground of retrenchment.
In protest of their dismissal, petitioners filed separate complaints for illegal dismissal and unfair labor practice before the Regional Arbitration Branch No. 6 in Bacolod City.

On March 4, 1991, Labor Arbiter Buenaventura C. Cordova, Jr. rendered a decision:

The complaints were dismissed on the merits regarding reinstatement.
Petitioners were awarded separation pay of P4,005.00 each, amounting to a total of P40,050.00 collectively.

Pending appeals before the National Labor Relations Commission (NLRC) were in progress when, on multiple occasions (May 7, June 3, and July 9, 1991), petitioners executed separate affidavits.
In these affidavits, petitioners stated their intention to withdraw the appeal since the separation pay had been received in full in accordance with the March 4, 1991 decision.
The affidavits were made after a full explanation by Labor Arbiter Cordova, Jr. regarding their legal consequences.
These affidavits, however, were not submitted to the NLRC, leaving the tribunal unaware of the settlement reached by the parties.

Unaware of the withdrawal affidavits, the NLRC rendered a decision on July 16, 1991, favorable to petitioners by:

An "Entry of Judgment" indicated that the July 16, 1991 decision had become final and executory as of August 12, 1991.
Petitioners then moved for execution of the NLRC decision.
Private respondent opposed the motion, arguing that the earlier settlement (separation pay award) rendered the NLRC decision moot and academic.
On January 7, 1992, Labor Arbiter Cesar D. Sideno denied the execution motion, closing and terminating the case by recognizing the settlement.
Subsequent NLRC resolutions on July 14, 1992, and then on September 28, 1992, vacillated on enforcing or reconsidering the previous order, with the NLRC ultimately reverting to uphold the case closure based on the settlement.

Petitioners argued that the July 16, 1991 decision was final and executory and could not be invalidated due to the settlement.
They contended that the affidavits withdrawing the appeal violated constitutional protections for labor because they allegedly resulted from economic difficulties and were coerced.
The petition sought to set aside the NLRC’s determination that its decisions rendered moot by the settlement the earlier March 4, 1991 award was sufficient and binding.

Whether the separate affidavits voluntarily signed by petitioners, withdrawing their appeal after having received separation pay, effectively and conclusively nullified further claims for reinstatement and back wages.
Whether the NLRC abused its discretion by declaring its July 16, 1991 decision and the subsequent July 14, 1992 resolution moot and academic on the basis of the settlement reached via the March 4, 1991 award.
Whether the petitioners’ claim that the joint affidavits violated constitutional rights due to alleged economic or coercive pressures is tenable.
Whether petitioners can later repudiate a compromise settlement that was voluntarily entered into and duly explained to them by the Labor Arbiter.