Quitclaim: the four tests from the Supreme Court
In Goodrich Manufacturing v. Ativo, G.R. No. 188002, February 1, 2010, the Supreme Court said the law looks with disfavor on quitclaims obtained by pressure. But it gives effect to a quitclaim if the employer proves four things:
- The employee executed it voluntarily
- There was no fraud or deceit
- The consideration is credible and reasonable
- It is not contrary to law, public order, public policy, morals or good customs
Example
Illustrative example only. You computed what you are owed: ₱48,000. The paper offers ₱46,500 and you read it with time to think. That looks like a reasonable settlement. If the paper offers ₱9,000 and HR says sign now or get nothing, write down what happened and how much was short.
⚠️ Tandaan
The Court quoted Periquet: a waiver that was voluntary and is a reasonable settlement is binding and may not later be disowned simply because of a change of mind. In Goodrich the employees lost on that point. So do the math before you sign, not after.
Bago pumirma
- ☐ Compute what you are owed, line by line
- ☐ Compare it with the amount in the paper
- ☐ Read every sentence and ask questions
- ☐ Keep a copy of what you sign
Quitclaim check, handa na: sagutan bago pumirma 👇
Basis: Goodrich Manufacturing Corp. v. Ativo, G.R. No. 188002, February 1, 2010 (Lawphil).