Case Digest (G.R. No. 178083) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Flight Attendants and Stewards Association of the Philippines (FASAP) vs. Philippine Airlines, Inc., Patria Chiong and the Court of Appeals (G.R. No. 178083, March 13, 2012), petitioner FASAP challenged the June–July 1998 retrenchment of 1,400 cabin crew personnel by respondent Philippine Airlines, Inc. (PAL). FASAP filed before the Labor Arbiter a complaint for illegal dismissal and unfair labor practice, asserting that PAL acted in bad faith, failed to adopt fair and reasonable selection criteria, and neglected less drastic cost‐cutting measures. The Labor Arbiter, then the National Labor Relations Commission (NLRC), and the Court of Appeals found that PAL suffered severe financial losses, underwent corporate rehabilitation and suspension of payments under PD 902-A, and validly retrenched employees. On July 22, 2008, a Third Division of the Supreme Court reversed the CA decision, held PAL guilty of illegal dismissal, ordered reinstatement or payment of backwages and attorne Case Digest (G.R. No. 178083) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Antecedents
- Flight Attendants and Stewards Association of the Philippines (FASAP) filed a petition for review on certiorari (G.R. No. 178083) after the Court of Appeals (CA) on August 23, 2006 affirmed the NLRC’s setting aside of a labor arbiter’s finding of unlawful retrenchment.
- On July 22, 2008, the Supreme Court Third Division reversed the CA, found Philippine Airlines, Inc. (PAL) guilty of illegal dismissal, and ordered reinstatement or payment of backwages to 1,400 cabin crew.
- PAL moved for reconsideration; on October 2, 2009, the Special Third Division denied the motion with finality and reduced attorney’s fees.
- PAL obtained leave to file a second motion for reconsideration in January 2010 under the Internal Rules of the Supreme Court (IRSC), thus reopening the July 2008 decision and October 2009 resolution.
- Changes in Division membership led to re-raffle to the Second Division, which on September 7, 2011 denied PAL’s second motion for reconsideration.
- PAL’s counsel sent letters to the Clerk of Court questioning successive transfers and ponentes; docketed as A.M. No. 11-10-1-SC, these prompted an October 4, 2011 en banc resolution recalling the September 2011 ruling and re-raffling the case.
- Substantive Background
- In mid-1998, PAL, beset by losses from the 1997 Asian financial crisis and a crippling pilots’ strike, implemented a retrenchment and demotion program affecting some 1,400 cabin crew.
- FASAP admitted PAL’s financial troubles but challenged the manner of selection—alleging lack of standard and bad faith.
- PAL was placed under corporate rehabilitation and receivership by the Securities and Exchange Commission (SEC) in June 1998 and reorganized under a stand-alone rehabilitation plan.
Issues:
- Procedural Issues
- Validity of the Court en banc’s October 4, 2011 resolution recalling the Second Division’s September 7, 2011 ruling.
- Whether PAL’s second motion for reconsideration, filed after leave was granted, may be entertained.
- Substantive Issues
- Did PAL lawfully retrench its 1,400 cabin crew?
- Did PAL present sufficient proof of serious financial losses justifying retrenchment?
- Did PAL act in good faith in executing the retrenchment program?
- Did PAL apply fair and reasonable criteria in selecting those retrenched?
- Assuming valid retrenchment, were the quitclaims of retrenched employees validly and voluntarily executed?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)