- Petitioner
- Felipe O. Magbanua
- Respondent
- Rizalino Uy
- Citation
- G.R. No. 161003
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Panganiban, J.
- Decided
- May 6, 2005
Summary
This case involves the validity of compromise agreements and waivers executed after a final Supreme Court judgment awarding wage differentials to eight workers. After receiving partial payment, the workers executed waivers compromising their remaining claims. The Labor Arbiter accepted the compromise and closed the case, but the NLRC reversed and ordered execution of the full judgment. The Court of Appeals reinstated the Labor Arbiter's decision. The Supreme Court affirmed, ruling that compromise agreements after final judgment are valid when voluntarily executed and comply with contract requirements. The Court held that Article 2040 of the Civil Code does not prohibit such agreements but only allows rescission when parties are unaware of the final judgment. The compromise agreement validly novated the judgment obligation, and the workers' waivers were binding despite the absence of counsel during execution.