Case Digest (G.R. No. 124841)
Facts:
Peftok Integrated Services, Inc. v. National Labor Relations Commission and Eduardo Abugho, et al., G.R. No. 124841, July 31, 1998, Supreme Court Third Division, Purisima, J., writing for the Court.Petitioner PEFTOK Integrated Services, Inc. (PEFTOK) sought certiorari under Rule 65 to set aside an NLRC decision that dismissed PEFTOK's appeal from a labor arbiter's monetary award in favor of several security guards including Eduardo Abugho and others. The labor arbiter (Noel Augusto S. Magbanua) had ordered respondents—identified in the award as PEFTOK Security Agency, Timber Industries of the Philippines, Inc. (TIPI) and Union Plywood Corporation—to pay specific sums to twelve complainants, aggregating P342,598.52, and dismissed other claims for lack of merit. A sheriff's return showed partial execution: TIPI paid fifty percent of its shared obligation and the guards executed quitclaims/statements effecting a fifty-percent compromise of benefits.
On October 13, 1989, Abugho, Claro Mendez and Leonardo Daluperi executed a waiver purportedly barring claims against PEFTOK for the period ending June 30, 1989. On May 29, 1992, Abugho, Fidel Sabellina, Daluperi, Mendez and Reynaldo Maasin executed another waiver and quitclaim described as renouncing claims against PEFTOK for the period ending March 15, 1998 (stated in the record). Subsequently, these guards executed affidavits saying the quitclaims were prepared by PEFTOK and that they signed under fear of not being paid or of losing their jobs—i.e., under coercion and without understanding the English-language documents. The guards contended the waivers were contrary to public policy.
Labor Arbiter Henry F. Te granted the guards' prayer for an alias writ of execution on June 19, 1995. PEFTOK filed an appeal to the NLRC, but the NLRC dismissed that appeal as late-filed: PEFTOK allegedly received the arbiter's decision on June 30, 1995 and filed its appeal only on July 17, 1995, beyond the 10-day period to appeal. The Solicitor General, in a comment, urged dismissal of PEFTOK's certiorari petition as premature for failure to file a motion for reconsideration before invoking the Court's Rule 65 remedy, and reiterated that employee quitclaims are generally against public policy.
The NLRC decision under review (dated February 26, 1995) was affirmed by the Court. The Supreme Court considered (a) the jurisdictional requirement of timely appeal and posting of cash or surety bond to perfect ...(Pro-only)
Issues:
- Was the petition filed under Rule 65 premature for failure to avail of administrative remedies (i.e., failure to file a motion for reconsideration before the NLRC)?
- Was PEFTOK's appeal to the NLRC jurisdictionally defective for late filing and failure to post the required cash or surety bond?
- Were the quitclaims and waivers executed by the employees valid and enforceable to...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)