G.R. No. 108734 - Concept Builders, Inc. vs. National Labor Relations Commission

Petitioners: Alfredo Veloso and Edito Liguaton, employees who initiated the dispute.
Respondents: Department of Labor & Employment; private respondent, Noah’s Ark Sugar Carriers; and Wilson T. Go, representing the employer’s interests.

A complaint was filed by the petitioners along with several co-employees against the private respondent alleging unfair labor practices, underpayment, non-payment of overtime, holiday, and other benefits.
The lower court rendered a favorable decision for the complainants on October 6, 1987, awarding monetary relief.
A motion for reconsideration (treated as an appeal) was filed but eventually dismissed in a resolution dated February 17, 1988.

While the private respondent’s motion for reconsideration and recomputation was still pending, petitioners executed quitclaims:

Petitioner Alfredo Veloso, through his wife Connie, signed a Quitclaim and Release on April 15, 1988, in exchange for P25,000.00. His counsel, Atty. Gaga Mauna, acknowledged receipt of the consideration and manifested “Satisfaction of Judgment.”
Petitioner Edito Liguaton relied on a similar arrangement by filing a motion to dismiss his complaint, based on a Release and Quitclaim dated July 19, 1988, in consideration of P20,000.00 received from the private respondent.

The petitioners later impugned these releases on September 20, 1988, contending that they were forced to sign due to "extreme necessity."

The Undersecretary of Labor, in an Order dated December 16, 1988, rejected the petitioners’ contention on the grounds of coercion and approved the compromise agreements.
The quitclaims were executed with proper assistance and formalities:

Veloso’s quitclaim was notarized in the presence of his counsel and attested by Atty. Ferdinand Magabilin, Chief of the Industrial Relations Division of the National Capitol Region of the DOLE.
Liguaton’s quitclaim was notarized by his counsel, Atty. Leopoldo Balguma, who initially pursued a different argument regarding the signing but later relied on the same document.

The bookings in the records reflect that even though the petitioners now claimed "dire necessity" as the basis for voiding the agreements, all evidence pointed to their voluntary and informed execution of the releases.

Whether the quitclaim and release agreements signed by Veloso and Liguaton were voluntarily executed and legally binding.
Whether the claims of having been coerced into signing—as alleged by the petitioners under the banner of “dire necessity”—justify annulling the releases.

Whether the alleged extreme necessity constitutes sufficient coercion, misrepresentation, or fraud to render the compromise agreements void.
Whether reopening the dispute based on subsequent regret or a change in assessment of the monetary awards is legally tenable.

Whether the approval by the DOLE, as well as the procedural regularity in the execution of the quitclaims, bars the petitioners from contesting their settlements.