G.R. No. 265117 - Antonio Abiang y Cabonce vs. People

On March 14, 2003, Quality Guards Services and Investigation Agency (QGSIA) hired petitioner Rafael B. Quillopa as a security guard and assigned him to various posts, the last being the West Burnham Place Condominium in Baguio City.
On September 28, 2010, petitioner was informed by QGSIA’s deputy manager, Rhegan Basabica, that he would be placed on a "floating status" pending a new assignment.
Despite petitioner’s repeated follow-ups at the QGSIA office, he was not given any new assignment due to the alleged nonavailability of vacancies, resulting in an extended period on floating status.

On November 11, 2010, petitioner filed his First Complaint before the National Labor Relations Commission (NLRC) for money claims, which included wages, overtime pay, premium pay for holidays and rest days, night shift differentials, 13th month pay, and service incentive leave pay.
An amicable settlement was reached, as evidenced by the Waiver/Quitclaim and Release executed on February 3, 2011, wherein petitioner acknowledged withdrawal of his complaint and receipt of a total amount of ₱10,000.00 in settlement of all claims arising from his employment.
The Labor Arbiter subsequently approved the settlement and dismissed the First Complaint with prejudice.

On September 14, 2011, petitioner filed a Second Complaint before the NLRC, this time alleging illegal dismissal with a prayer for full backwages, separation pay, and attorney’s fees.
Petitioner contended that his prolonged placement on floating status—lasting for almost one year—constituted a constructive dismissal, as his continued waiting without assignment effectively terminated the employer-employee relationship.

Respondents argued that the Waiver/Quitclaim and Release had severed the employer-employee relationship, thereby baring petitioner from pursuing any further claims against them.
The Labor Arbiter ruled in favor of petitioner on January 30, 2012, awarding him separation pay, backwages, and attorney’s fees, finding that the waiver only dealt with the money claims of the First Complaint and did not cover issues pertaining to illegal dismissal.
The NLRC, in its decision dated May 31, 2012, affirmed the Labor Arbiter’s ruling, holding that petitioner was constructively dismissed for being on floating status beyond the allowable period. A subsequent resolution dated August 14, 2012, denied respondents’ motion for reconsideration by the NLRC.
The Court of Appeals (CA) reversed the NLRC ruling in its Decision dated February 19, 2014, dismissing the Second Complaint on the ground that the Waiver/Quitclaim and Release terminated the employer-employee relationship, compounded by the fact that petitioner filed his illegal dismissal claim more than seven months after the settlement.
A motion for reconsideration of the CA ruling was denied in a Resolution dated July 25, 2014, leading petitioner to elevate the matter by filing the present petition for review on certiorari.

Whether the Court of Appeals correctly ruled that the Waiver/Quitclaim and Release, which settled the money claims in the First Complaint, precluded petitioner from filing the Second Complaint for illegal dismissal.

The primary issue centers on whether the settlement agreement extinguished all causes of action arising from petitioner’s employment or only those specifically enumerated in the First Complaint.
A related issue is the interpretation of petitioner’s extended floating status and whether it legally amounts to a constructive dismissal given the statutory threshold of six months.