G.R. No. 204803 - Almagro vs. Philippine Airlines, Inc.

Petitioners – former senior pilots of Philippine Airlines, Inc. (PAL) – filed a petition for review on certiorari under Rule 45 to nullify the Court of Appeals’ (CA) December 7, 2012 Amended Decision in CA-G.R. SP No. 111466.
The petition seeks to challenge earlier decisions by the National Labor Relations Commission (NLRC) and the Labor Arbiter involving their complaints for illegal dismissal and monetary claims, which stem from a labor dispute in the 1990s between PAL and the Airline Pilots Association of the Philippines (ALPAP).

ALPAP, recognized as the legitimate labor organization for PAL’s commercial pilots, initiated a strike after filing a notice on December 9, 1997, citing unfair labor practices and union-busting by PAL.
The Department of Labor and Employment (DOLE) Secretary assumed jurisdiction over the dispute on December 23, 1997.
Despite the Secretary’s intervention and a return-to-work order issued on June 7, 1998, ALPAP commenced the strike on June 5, 1998 and persisted until June 26, 1998.
On June 26, 1998, employees who attempted to return to work signed PAL’s security logbook marked “Return to Work Returnees/Compliance,” but PAL refused their readmission based on the lapsed deadline (June 9, 1998).

Following PAL’s refusal to accept returning employees, ALPAP filed an illegal lockout case with the NLRC on June 29, 1998, which was consolidated with the strike case.
The DOLE Secretary, in a Resolution dated June 1, 1999, declared the loss of employment status of all ALPAP members who participated in the strike and dismissed the illegal lockout case.
ALPAP’s subsequent motion on January 13, 2003, to determine which members should be reinstated was denied based on the finality of earlier adverse rulings concerning the strike participants.
Separate illegal dismissal complaints were filed by petitioners before the NLRC after being refused reemployment.

The Labor Arbiter rendered a Decision in petitioners’ favor on August 25, 2000, but this was later set aside by the NLRC on January 10, 2002 due to issues concerning PAL’s rehabilitation.
After PAL’s successful rehabilitation was declared, proceedings resumed. In the July 16, 2008 Decision, the Labor Arbiter dismissed petitioners’ consolidated complaints based on their participation in the illegal strike, evidenced by the signing of the PAL security logbook and corroborative photographic evidence.
The NLRC affirmed the Labor Arbiter’s ruling, emphasizing that the petitioners, by their behavior and signatures, acted in concert with the union and defied the return-to-work order.
On appeal, the CA initially sided with petitioners under Rule 65, awarding backwages and monetary claims; however, upon PAL’s motion for reconsideration, the CA reversed its earlier decision in its Amended Decision, relying heavily on the evidentiary value of the logbook and the precedent set in Airline Pilots.

Their signatures on the logbook do not amount to an admission of participation in the illegal strike but were executed in hope of being reinstated after dismissal.
Their approved official leaves during the period in question should exempt them from classification as strikers.
The application of Airline Pilots as binding precedent is inappropriate because of differences in evidence and party representation.

The petition is procedurally defective in certain respects.
The CA’s Amended Decision, affirming the NLRC and Labor Arbiter decisions, is legally supported by the evidence, particularly the PAL security logbook.
PAL’s enforcement of the return-to-work order, which effectively terminated non-compliant employees, was in accordance with law.

The issue before the Supreme Court is limited to whether the CA correctly resolved the presence or absence of grave abuse of discretion on the part of the NLRC in light of the administrative record and applicable law under Rule 45.
The Court’s review is confined to matters of law, specifically whether the factual findings—such as the evidentiary weight of the logbook signatures and associated evidence—were legally sufficient to affirm the dismissal of the petitioners’ claims.

Whether the signatures in the PAL security logbook are sufficient evidence to establish that petitioners were strikers who defied the return-to-work order.

Does the signing of the logbook conclusively demonstrate participation in the strike or merely indicate an attempt to return to work?
Is the argument that petitioners were on official leave sufficient to exclude them from being classified as strikers?

Whether the application of the doctrines of res judicata (conclusiveness of judgment) and stare decisis precludes petitioners from relitigating issues already settled by prior decisions (e.g., Airline Pilots and Rodriguez).

Whether the CA, in relying on the evidentiary record and prior rulings, committed grave abuse of discretion in affirming the NLRC’s dismissal of petitioners’ complaints.