G.R. No. 234207 - People vs. Cristobal y Ambrosio

Petitioner was employed as a salesman by the private respondent starting on or about December 1, 1982.
His compensation package included a monthly salary of P1,300.00 and a commission of 3% on all sales.

On August 31, 1984, petitioner submitted his letter of resignation.
Along with the resignation letter, petitioner executed a quitclaim releasing the private respondent from any further money claims that might otherwise arise from his employment.

After his resignation, petitioner received three checks dated October 10, October 16, and October 26, 1984.

Petitioner later filed a complaint with the Ministry of Labor and Employment for non-payment of commissions (and also for unpaid benefits such as sick leaves, vacation leaves, and 13th month pay).

The case was referred to a labor arbiter who, after requiring both parties to submit their respective position papers, issued a decision on March 18, 1986 awarding petitioner a total of P35,273.92 for unpaid commissions (and alleged overprice).
Private respondent appealed the labor arbiter’s decision before the National Labor Relations Commission (NLRC).
On June 30, 1987, the NLRC reversed the labor arbiter’s decision and dismissed petitioner’s complaint for lacking merit.

Petitioner filed the present petition, arguing that despite his resignation and the quitclaim executed, he was not barred from claiming money due for unpaid commissions.
The Supreme Court identified evidence suggesting a parallel agreement between the parties by noting:

The fact that petitioner received three checks after his resignation.
The logical conclusion that the issuance of these checks, with one already encashed, indicated an understanding that commissions were still due.

The Court also observed that while the quitclaim released the private respondent from previous claims, it did not preclude claims where a separate understanding (or parallel agreement) for commission payment was evident.

Whether an employee who has resigned and executed a quitclaim releasing his employer from any money claims is thereby precluded from pursuing further claims, particularly for unpaid commissions.

Whether the receipt and partial encashment of the post-resignation checks can be construed as evidence of a parallel agreement for the payment of commissions.
Whether petitioner is entitled to claim additional amounts (overprice) not originally prayed for in his complaint vis-à-vis the commissions.