Case Digest (G.R. No. 204803)
Facts:
This is Salvador P. Almagro, et al. v. Philippine Airlines, Inc., et al., G.R. No. 204803, September 12, 2018, First Division, Jardeleza, J., writing for the Court. Petitioners are former senior pilots of Philippine Airlines, Inc. (PAL); respondents are Philippine Airlines, Inc., Lucio Tan, and Jose Antonio Garcia. The petition sought review under Rule 45 of the Court of Appeals’ Amended Decision in CA-G.R. SP No. 111466.The dispute arose from the 1997–1998 labor conflict between PAL and the Airline Pilots Association of the Philippines (ALPAP). After ALPAP filed a notice of strike on December 9, 1997, the DOLE Secretary assumed jurisdiction on December 23, 1997. ALPAP declared a strike on June 5, 1998; the Secretary issued a return-to-work order on June 7, 1998 imposing a June 9, 1998 deadline. Some pilots attempted to report only on June 26, 1998 and signed PAL’s “Return to Work Compliance/Returnees” logbook; PAL refused to accept them. The DOLE Secretary, in a June 1, 1999 Resolution, declared loss of employment status of officers and members who participated in the strike and dismissed ALPAP’s illegal lockout complaint; that Resolution was litigated and sustained in G.R. No. 152306.
Several individual illegal dismissal complaints followed. Petitioners filed consolidated NLRC complaints: NLRC‑NCR No. 00‑07‑05400‑98 (Almagro) and NLRC‑NCR No. 00‑11‑08918‑98 (Cruz, Juliano, Novenario, Canete). After PAL’s rehabilitation proceedings produced a stay, the NLRC initially set aside a Labor Arbiter’s August 25, 2000 decision in favor of petitioners in 2002, citing PAL’s rehabilitation; the stay was lifted after the Securities and Exchange Commission declared rehabilitation successful on September 28, 2007.
On resumption, Labor Arbiter Donato G. Quinto, Jr. rendered a July 16, 2008 Decision dismissing the consolidated complaints, finding petitioners participated in the illegal strike and defied the return-to-work order — giving weight to the PAL logbook and photographs. The NLRC affirmed in its May 15, 2009 Decision. Petitioners sought relief by certiorari under Rule 65 in the Court of Appeals; the CA initially granted certiorari and, in a January 31, 2012 Decision, set aside the NLRC’s ruling and awarded full backwages and related monetary claims to petitioners.
PAL moved for reconsideration; the CA, recalling this Court’s rulings in the ALPAP cases, issued an Amended Decision dated December 7, 2012 reversing its January 31 ruling a...(Subscriber-Only)
Issues:
- Did the Court of Appeals correctly determine that the National Labor Relations Commission did not commit grave abuse of discretion in affirming the Labor Arbiter’s dismissal of petitioners’ illegal dismissal complaints?
- Are petitioners bound by this Court’s prior rulings (particularly Airline Pilots Association of the Philippines v. Philippine Airlines, Inc., G.R. No. 168382) that the PAL logbook signatures of June 26, 1998 establish participation in the illegal strike and defiance of the return-to-work order?
- Do the doctrines of conclusiveness of judgment (res judicata) and stare decisis bar petitioners f...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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