This case has been cited 2 times or more.
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2006-09-05 |
CALLEJO, SR., J. |
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| The nature of a compromise is spelled out in Article 2028 of the New Civil Code: it is "a contract whereby the parties, by making reciprocal concessions, avoid litigation or put an end to one already commenced." Parties to a compromise are motivated by "the hope of gaining, balanced by the dangers of losing."[26] It contemplates mutual concessions and mutual gains to avoid the expenses of litigation, or, when litigation has already begun, to end it because of the uncertainty of the result.[27] Article 227 of the Labor Code of the Philippines authorizes compromise agreements voluntarily agreed upon by the parties, in conformity with the basic policy of the State "to promote and emphasize the primacy of free collective bargaining and negotiations, including voluntary arbitration, mediation and conciliation, as modes of settling labor or industrial disputes."[28] As the Court held in Reformist Union of R.B. Liner, Inc. v. NLRC,[29] the provision "bestows finality to unvitiated compromise agreements," particularly if there is no allegation that either party did not comply with what was incumbent upon them under the agreement. The provision reads:ART. 227 Compromise Agreements. - Any compromise settlement, including those involving labor standard laws, voluntarily agreed upon by the parties with the assistance of the Bureau or the regional office of the Department of Labor, shall be final and binding upon the parties. The National Labor Relations Commission or any court shall not assume jurisdiction over issues involved therein except in case of noncompliance thereof or if there is prima facie evidence that the settlement was obtained through fraud, misrepresentation, or coercion. Thus, a judgment rendered in accordance with a compromise agreement is not appealable, and is immediately executory unless a motion is filed to set aside the agreement on the ground of fraud, mistake, or duress, in which case an appeal may be taken against the order denying the motion.[30] Under Article 2037 of the Civil Code, "a compromise has upon the parties the effect and authority of res judicata," even when effected without judicial approval; and under the principle of res judicata, an issue which had already been laid to rest by the parties themselves can no longer be relitigated.[31] | |||||
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2005-10-25 |
CARPIO, J. |
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| We agree with the findings of the Labor Arbiter and the NLRC that RAMATEK illegally dismissed Anelia. This Court defers to the factual findings of labor officials, who possess the expertise in matters within their jurisdiction, provided substantial evidence support such factual findings.[19] Thus, absent any proof that the factual findings of the Labor Arbiter and the NLRC are capricious or arbitrary, such findings have conclusive effect on this Court and deserve finality.[20] | |||||