Facts:

This case involves two consolidated petitions for certiorari (G.R. No. L-33705 and G.R. No. L-35206) brought forward by the Air Line Pilots Association of the Philippines (ALPAP) representing different factions within the organization. The Gaston Group, led by Captain Felix Gaston, and the Gomez Group, led by Captain Ben Hur Gomez, contested the legitimacy of each other's claims to being the duly elected representation of the pilots employed by the Philippine Air Lines (PAL). The disputes culminated from various events, including a certification petition filed on January 2, 1971, by the Gomez Group seeking to be recognized as the sole collective bargaining representative of all active pilots. The ALPAP (Gaston) opposed this, arguing that the labor court lacked jurisdiction over such a claim, prompting Judge Joaquin Salvador to certify the Gomez Group as the official representative on May 29, 1971. Following this decision, numerous pilots from the Gaston Group retired or resi

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Facts:

Consolidation of Two Petitions

• Petition L-33705 filed by ALPAP (Gaston) challenged the Court of Industrial Relations’ jurisdiction in determining:

- Which set of officers elected by two competing factions (Gaston vs. Gomez) was lawfully constituted as the sole collective bargaining representative of Philippine Air Lines (PAL) pilots. - Which faction was entitled to the union’s corporate name, office, and funds. - Reinstatement and/or return to work in PAL; or, alternatively, payment of retirement and/or separation benefits.

The Union Elections and Membership Dispute

• ALPAP held a general membership meeting on October 30, 1970, where 221 of 270 members approved an amendment to its Constitution and By-Laws permitting active members forced to retire, resign, or terminated for union activities to either remain or resign formally.
• On December 18–22, 1970, an election was held resulting in:

- Felix C. Gaston’s election as president by 180 votes. - A separate meeting on December 23, 1970, by about 45 pilots (who did not tender their resignation/retirement) electing Ben Hur Gomez as president.

Industrial Court Proceedings and Orders

• In the certification petition (L-33705), Judge Joaquin M. Salvador’s decision (May 29, 1971) certified ALPAP (non-resigning, PAL-employed pilots) with Ben Hur Gomez as collective bargaining representative.

- The decision cited factors such as: - Return-to-work orders issued by Judge Ansberto P. Paredes due to ongoing strikes. - Subsequent events where some pilots, including Gaston, were dismissed by PAL following non-compliance or selective participation in return-to-work orders. - Denying motions for reconsideration regarding the certification results. - Adopting a resolution (June 19, 1972) suspending hearings on the petitions for reinstatement pending the decision in L-33705.

Additional Proceedings and Related Matters

• Subsequent filings involved:

- Motion for contempt filed by Felix Gaston claiming unjust dismissal. - Petitions by a group of pilots for reinstatement to PAL or, alternatively, for retirement or separation pay benefits.

Issue:

Jurisdictional and Procedural Questions

• Whether the Court of Industrial Relations had jurisdiction to determine which faction was the duly elected collective bargaining representative.
• Whether a certification proceeding in an industrial dispute can include issues seemingly ancillary to the actual representation matter, such as the validity of amendments to a union’s constitution.
• Whether the suspension of hearings on the reinstatement petitions (L-35206) pending the resolution of L-33705 constitutes grave abuse of discretion or a jurisdictional error.

Validity of the Union’s Amendment and Membership

• Whether the amendment to ALPAP’s Constitution and By-Laws—allowing non-PAL employees to remain as members—was adopted in accordance with the union’s prescribed procedures.
• Whether the statutory definition of a “labor organization” may extend membership beyond employees of a single employer.
• If the restrictive interpretation of union membership, limiting it to PAL’s employees, is legally sound given the language of R.A. 875.

Effects of Mass Retirement/Resignation

• Whether the mass retirement and resignation actions by a group of pilots should be deemed as a legitimate concerted activity or an intentional abandonment of their employment relationship to evade court jurisdiction.
• The consequences of such actions on the pilots’ rights to reinstatement, retirement, or separation benefits.
• Whether the industrial court had the power to order the forfeiture of rights and privileges (retirement benefits) for pilots who resigned or retired in contravention of return-to-work orders.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)