Title
Supreme Court
Halaguena vs. Philippine Airlines, Inc.
Case
G.R. No. 243259
Decision Date
Jan 10, 2023
Female PAL flight attendants challenged a CBA provision mandating earlier retirement for women (55) than men (60). The Supreme Court ruled it discriminatory, void, and unconstitutional, upholding gender equality.

Case Digest (G.R. No. 243259)
Expanded Legal Reasoning Model

Facts:

  • Parties and Collective Bargaining Agreement
    • Petitioners are female flight attendants of Philippine Airlines, Inc. (PAL) and members of the Flight Attendants and Stewards Association of the Philippines (FASAP).
    • PAL and FASAP entered into a 2000–2005 CBA containing Section 144(A), which provides compulsory retirement at age 55 for female cabin attendants and age 60 for male cabin attendants.
  • Procedural History
    • July 29, 2004: Petitioners filed a petition for declaratory relief in RTC Makati (Civil Case No. 04-886), seeking nullification of Section 144(A) as discriminatory; RTC issued TRO and writ of preliminary injunction.
    • August 31, 2005: Court of Appeals (CA) annulled RTC proceedings for lack of jurisdiction.
    • October 2, 2009: Supreme Court (Third Division) reversed CA and remanded to RTC.
    • February 18 & July 30, 2010: RTC granted revival of case and writ of preliminary injunction; later lifted on bond.
    • May 22, 2015: RTC declared Section 144(A) null and void for discrimination, awarded damages and attorney’s fees.
    • October 9, 2015: RTC denied reconsideration by PAL.
    • May 31 & November 19, 2018: CA reversed RTC, upheld validity of Section 144(A) as voluntarily ratified and non-illegal.
    • January 11, 2019: Petitioners filed this Petition for Review on Certiorari before the Supreme Court en banc.
  • Issue on Review
    • Whether Section 144(A) of the PAL-FASAP 2000–2005 CBA is discriminatory against women and void as contrary to the Constitution, Labor Code, public policy, and international conventions.

Issues:

  • Is Section 144(A) of the PAL-FASAP 2000–2005 CBA—mandating compulsory retirement at 55 for female cabin attendants and 60 for male—discriminatory against women and therefore void for being contrary to the Constitution, the Labor Code, the Magna Carta of Women, the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW), and public policy?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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