FASAP v NLRCLabor: Compromise and WaiverFACTS: Flight Attendants and Stewards Association of the Philippines v PAL: third of such case, they are petitioning the SC to set aside CAs decision setting aside NLRCs finding of illegal retrenchment against FASAP. PAL executed a retrenchment program claiming losses due to the Asian Financial Crisis. It states that it would have to use Plan 14 (planes) in order to alleviate itself from losses. Such plan would necessitate the retrenchment of several employees. Probationary employees were first terminated Regular employees were then retrenched based on PALs own assessments However, Plan 14 was not executed. Plan 14 expanded and was actually Plan 22. Thereafter, PAL recalled the probationary employees it previously removed. Nonetheless, it still continued with retrenchment of the other regular employees. FASAP claims illegal retrenchment on the ff grounds: PAL failed to exhaust all means of cost-cutting measures before resorting to retrenchment as required by Law PAL selected only 1997 as the sole year to base their performance review from which they will base who will be retrenched Seniority was disregarded in violation of the CBA PAL maliciously misrepresented when it says it can only fly 14 planes where in fact they flew 22 PAL did not use any reasonable criteria in effecting retrenchment QUITCLAIMS/WAIVERS: FASAP employees who were retrenched signed quitclaims/waivers COMPROMISE: In order to keep PAL running and prevent its closure, PALEA entered into an agreement with PAL brokered by then President Estrada. Compromise includes suspension of the CBA for 10 years, PALEA employees receive shares of stock of PAL, etc etc. (Not relevant to this case)ISSUE: WoN there was valid retrenchment