Facts:

On October 21, 1988, Vicente S. Almario was employed by Philippine Airlines, Inc. (PAL) as a Boeing 747 Systems Engineer. By April 28, 1995, he successfully bid for the position of Airbus 300 (A-300) First Officer, which necessitated additional training funded by PAL. He undertook over five months of training that included ground schooling in Manila and flight simulation in Melbourne, Australia. After completing this training, Almario worked as an A-300 First Officer for eight months before resigning on September 16, 1996, citing "personal reasons." On September 27, PAL's Vice President for Flight Operations sent Almario a letter stating that the company had invested approximately PHP 786,713.00 in his training, and urged him to reconsider his resignation, warning him that he might be required to reimburse this amount if he did not serve a stipulated period of three years.

Despite this letter, Almario proceeded with his resignation. Subsequently, his counsel sought

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Facts:

Employment and Promotion Background

• Vicente S. Almario was initially hired by Philippine Airlines, Inc. (PAL) as a Boeing 747 Systems Engineer.
• Almario subsequently bid for the promotion to Airbus 300 (A-300) First Officer and was accepted based on qualification and seniority.
• The promotion required additional training, which PAL provided at their expense, consisting of over five months of ground schooling in Manila and flight simulation in Melbourne, Australia.

Training and Resignation

• Almario completed the training course on February 8, 1996, and served as A-300 First Officer.
• After rendering service for eight months, he tendered his resignation effective October 15, 1996, citing "personal reasons."
• Prior to his resignation, on September 27, 1996, PAL’s Vice President for Flight Operations sent him a letter urging him to reconsider his resignation.
• The letter stated that PAL had invested an estimated PHP786,713.00 in Almario’s training with the expectation that he would serve for a minimum of three (3) years.
• It warned that failure to serve for the specified period would require Almario to reimburse the company for the training costs along with damages.

Dispute Arising from the Training Cost Recovery

• Despite receiving the letter, Almario went through with his resignation.
• Subsequent correspondence from Almario’s counsel questioned PAL’s claim since Almario maintained that no written agreement regarding reimbursement was signed.
• After a series of follow-up letters and the release of necessary clearances for his benefits, PAL initiated a legal action on February 11, 1997, before the Makati Regional Trial Court (RTC).
• PAL sought reimbursement of PHP851,107 for training costs, plus attorney’s fees and litigation expenses.
• PAL based its claim on an innominate contract (do ut facias), arguing that its training investment was recoverable if Almario did not serve PAL for the required three-year period.

Procedural History and Agreement Provisions

• Almario, in his Answer with Special and Affirmative Defenses and Compulsory Counterclaims, denied any explicit obligation to render three years of service following the training.
• He cited the 1991–1994 Collective Bargaining Agreement (CBA) between PAL and the Airline Pilots Association of the Philippines (ALPAP) which, according to him, did not stipulate such a service requirement.
• The trial court ruled in favor of Almario by dismissing PAL’s complaint, though it partially awarded actual damages to Almario while denying his claims for moral damages and benefits related to the family trip pass.
• The Court of Appeals, in its March 31, 2005 decision, reversed the trial court decision and held Almario liable under:
• The provisions of the CBA (specifically Article XXIII, Section 1) emphasizing a three-year service period.
• Article 22 of the Civil Code, regarding unjust enrichment.
• It computed that Almario’s outstanding reimbursement amount was PHP559,739.90 after offsetting his eight months of service against the total training cost.

Further Evidences and Testimonies

• Testimonies from PAL officials, including the Senior Vice President for Flight Operations, confirmed that the training was provided with the expectation of a minimum three (3) year service period.
• Reference was made to prior DOLE rulings and the interpretation of Collective Bargaining Agreements that reinforce the recovery of training expenses, particularly the connection between age limits and training cost recovery.
• PAL also cited the principle of unjust enrichment, contending that Almario’s premature resignation unjustly benefited him at PAL’s expense.

Issue:

Whether the Court of Appeals erred in interpreting the Collective Bargaining Agreement (CBA) as an ordinary civil contract imposing an implied three-year service requirement on Almario.

• Consideration of whether the service obligation was negotiated and explicitly included in the CBA.
• The applicability of principles from Samahang Manggagawa sa Top Form Manufacturing-United Workers of the Philippines (SMTFM-UWP) v. NLRC regarding contract interpretation.

• Whether Article 22 of the Civil Code, which governs unjust enrichment, can be applied to recover training costs from Almario, given that no written agreement mandating reimbursement was signed by him.

Whether the provision of required training constitutes a legal ground that justifies entitlement to the benefit and precludes claims of unjust enrichment.

• Analysis of whether the acceptance of training inherently binds the trainee to a period of service.

• Whether PAL’s failure to honor the Family Trip Pass Benefit, which Almario and his family were unable to avail within one year from the date of his separation, constitutes unjust enrichment and consequent liability.

• Whether PAL is liable for malicious prosecution based on their handling of the matter and communication with Almario prior to his resignation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)