The petitioner was employed by GMCR, Inc. and took medical leave due to a lung condition. He requested retirement benefits under the collective bargaining agreement, but the company asked him to change his retirement date in exchange for payment. Petitioner agreed but later filed a complaint seeking full payment. The company argued he was estopped from filing due to a signed quitclaim and waiver. The court held the waiver invalid as petitioner was entitled to retirement benefits as a matter of right, and agreements contrary to public policy like protecting labor rights are invalid even if voluntarily agreed upon.
The petitioner was employed by GMCR, Inc. and took medical leave due to a lung condition. He requested retirement benefits under the collective bargaining agreement, but the company asked him to change his retirement date in exchange for payment. Petitioner agreed but later filed a complaint seeking full payment. The company argued he was estopped from filing due to a signed quitclaim and waiver. The court held the waiver invalid as petitioner was entitled to retirement benefits as a matter of right, and agreements contrary to public policy like protecting labor rights are invalid even if voluntarily agreed upon.
The petitioner was employed by GMCR, Inc. and took medical leave due to a lung condition. He requested retirement benefits under the collective bargaining agreement, but the company asked him to change his retirement date in exchange for payment. Petitioner agreed but later filed a complaint seeking full payment. The company argued he was estopped from filing due to a signed quitclaim and waiver. The court held the waiver invalid as petitioner was entitled to retirement benefits as a matter of right, and agreements contrary to public policy like protecting labor rights are invalid even if voluntarily agreed upon.
The petitioner was employed by GMCR, Inc. and took medical leave due to a lung condition. He requested retirement benefits under the collective bargaining agreement, but the company asked him to change his retirement date in exchange for payment. Petitioner agreed but later filed a complaint seeking full payment. The company argued he was estopped from filing due to a signed quitclaim and waiver. The court held the waiver invalid as petitioner was entitled to retirement benefits as a matter of right, and agreements contrary to public policy like protecting labor rights are invalid even if voluntarily agreed upon.
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QUITCLAIMS EVEN IF VOLUNTARILY AGREED ARE INVALID IF CONTRARY TO PUBLIC POLICY
AND WILL NOT BAR THE EMPLOYEE FROM BRINGING ACTIONS AGAINST THE EMPLOYER
ERNESTO MARTINEZ v NATIONAL LABOR RELATIONS COMMISSION, GMCR, INC.
(Formerly GLOBE MACKAY CABLE & RADIO CORP.), and MARK ANTHONY JAVIER
G.R. No. 118743 October 12, 1998
Facts: Respondent GMCR, Inc. employed petitioner as assistant credit and collection manage, at the inception of petitioners employment, respondent company made it clear thatemployees who were not eligible for membership in the bargaining unit and, therefore, not entitled to the benefits under the collective bargaining agreement, would be paid benefits which were at least equivalent to, if not higher than, those provided in the collective bargaining agreement. Petitioner was promoted to Credit and Collection Manager. etitioner was examined by Dr. Florencio A. Chavez, the company physician and a pulmonary and cardiology specialist, and found to be suffering from a severe restrictive and obstructive pulmonary defect with no reversible component. He took a sick leave from March 1 until July 15, 1992. He then requested for optional retirement benefits under the CBA dated July 16, 1992, the company replied that due to financial difficulties, they would agree if petitioner would change the date from July 16 to April 1992 to which the latter agreed. Petitioner was issued check for final payment, but he did not accept the same and filed a complaint seeking payment. LA rendered a judgment ordering respondent to pay, to which the latter appealed arguing that since petitioner already signed a quitclaim and waiver, he is already estopped from instituting this action.
Issue: WON, the waiver signed by petitioner was valid.
Held: No, the document signed was an invalid waiver and cannot bar him from bringing this action. Unlike petitioners waiver of the original date of his retirement, the consideration for which is the advance on his retirement benefits, the Release, Waiver and Quitclaim does not purport to have been made by petitioner for valuable consideration. Petitioner was, as a matter of right, entitled to his retirement benefits. Private respondents cannot condition their release to a quitclaim executed by petitioner. Even if voluntarily executed, agreements are invalid if they are contrary to public policy. This is elementary. The protection of labor is one of the policies laid down by the Constitution not only by specific provision but also as part of social justice.
