G.R. No. 198662 - Radio Mindanao Network, Inc. vs. Ybarola, Jr.

Respondents, Domingo Z. Ybarola, Jr. and Alfonso E. Rivera, Jr., were hired by Radio Mindanao Network, Inc. (RMN) on June 15, 1977, and June 1, 1983, respectively.
Both respondents eventually became account managers responsible for soliciting advertisements and servicing RMN’s clients.
On September 15, 2002, amidst RMN’s reorganization/restructuring, the services of both respondents were terminated.
They were paid separation amounts of ₱631,250.00 for Ybarola and ₱481,250.00 for Rivera.
In December 2002, the respondents executed release/quitclaim affidavits despite expressing dissatisfaction with their separation pay.

Dissatisfied with the separation pay, the respondents filed consolidated illegal dismissal complaints against RMN and its President, Eric S. Canoy.
Their claims included recovery of what they deemed the full benefits due to them and additional money claims, including attorney’s fees.
They claimed monthly salaries of ₱60,000.00 for Ybarola and ₱40,000.00 for Rivera, while the petitioners maintained that both received a salary of ₱9,177.00 as evidenced by payrolls.

On July 18, 2007, Labor Arbiter Patricio Libo-on dismissed the illegal dismissal complaint but ordered the payment of additional separation pay—₱490,066.00 for Ybarola and ₱429,517.55 for Rivera.
The labor arbiter adjusted the separation pay computation based on the respondents’ Certificates of Compensation Payment/Tax Withheld which indicated significantly higher annual salaries.
The National Labor Relations Commission (NLRC) later set aside the labor arbiter’s decision and dismissed the complaint, ruling that the withholding tax certificate was an unsuitable basis for computing separation pay, and that commissions generally do not form part of such computation.
The NLRC also upheld the validity of the respondents’ release/quitclaim affidavits by finding no evidence of coercion.
The respondents then secured relief from the Court of Appeals (CA) through a petition for certiorari under Rule 65. In its decision dated February 17, 2011, the CA:

Reinstated the labor arbiter’s separation pay award.
Rejected the NLRC’s exclusion of commissions as part of the respondents’ wages.
Declared the release/quitclaim affidavits invalid on grounds of unconscionable settlement terms and lack of voluntariness, noting that the compensation was deficient by at least ₱400,000.00 for each respondent.
Highlighted that the respondents delayed by three months in signing the release, suggesting coercion under dire circumstances.

The petitioners moved for reconsideration of the CA decision on September 23, 2011, which was denied.
Subsequently, the petitioners appealed to the Supreme Court through a petition for review on certiorari under Rule 45 of the Rules of Court, which was denied by a Resolution dated December 7, 2011.

The CA committed reversible error in not declaring Eric S. Canoy personally liable.
The CA misapplied the rule from Talam v. NLRC in the appreciation of release/quitclaim affidavits.
The respondents failed to prove that their commissions were earned through actual market transactions attributable to them.

The petitioners argued that the release/quitclaim affidavits should be given effect as voluntary and valid, citing that the respondents were intelligent, well-educated employees.
They contended that the award should not hold Canoy liable individually since there was no evidence of his personal involvement in their dismissal.

The issues had already been raised and resolved in prior proceedings.
The argument on Canoy’s personal liability was not raised in a timely manner and was thus final and conclusive.

In reply, the petitioners asked that their petition be reinstated to allow full consideration of the issues raised, particularly emphasizing that:

The CA’s reversal on the inclusion of commissions was a correct exercise of discretion.
The personal liability issue should still be entertained to avoid enforcement against Canoy.
The respondents failed to substantiate the claim that they were not in dire circumstances when signing the release/quitclaim.

Whether the respondents’ release/quitclaim affidavits, executed under alleged dire circumstances, should bar their claim for the full separation benefits to which they were entitled.

Was the execution of the release/quitclaim truly voluntary, or was it compelled by necessity?
Should unconscionable settlement terms invalidate the release/quitclaim despite its formal execution?

Whether commissions earned by the respondents should be considered part of their salaries for the purpose of computing separation pay.

Do the respondents’ commissions, corroborated by payroll documents and actual market transactions, form an integral part of their compensation?
Is the petitioners’ contention that the commissions were profit-sharing payments (and thus excluded from the computation) tenable?

Whether the CA erred in not expressly declaring Eric S. Canoy personally liable for the award given to the respondents.

Does the failure of the petitioners to timely raise the issue of Canoy’s personal liability preclude its consideration at the Supreme Court level?
How does the principle of estoppel apply in precluding the petitioners from revisiting this issue?

Whether the petitioners’ arguments on the proper appreciation of quitclaims, relying on Talam v. NLRC, are applicable given the different circumstances of the respondents.

Is the comparison between the circumstances of Talam and those of Ybarola and Rivera valid, particularly in light of their significantly longer service and the alleged deficiency in separation pay?