Case Digest (G.R. No. 243259)
Facts:
Petitioners are female cabin attendants of Philippine Airlines, Inc. and members of Flight Attendants and Stewards Association of the Philippines (FASAP) who challenged Section 144(A) of the PAL–FASAP 2000–2005 Collective Bargaining Agreement (CBA), which set compulsory retirement at 55 for females and 60 for males. The Regional Trial Court declared Section 144(A) void for discrimination on May 22, 2015, the Court of Appeals reversed on May 31, 2018, and petitioners filed a Rule 45 petition with the Supreme Court on January 11, 2019.
Issues:
- Is Section 144(A) of the PAL–FASAP 2000–2005 CBA discriminatory against women and therefore void under the Constitution, statutes, and international conventions?
- Does the CBA’s historical ratification or petitioners’ acceptance of retirement benefits estop them from challenging Section 144(A)?
Ruling:
The Court granted the petition. The May 31, 2018 Decision and November 19, 2018 Resolution of the Court of Appeals were reversed and set aside, and the May 22, 2015 Decision and October 9, 2015 Resolution of the Regional Trial Court were affirmed and reinstated. The Court held Section 144(A) void as discriminatory against female cabin attendants.
Ratio:
The Court found the compulsory retirement age distinction to be discrimination on the mere basis of sex in violation of the constitutional mandate to "ensure the fundamental equality before the law of women and men" (Article II, Section 14) and related labor protections. The respondent failed to adduce substantial evidence or a bona fide occupational qualification showing a reasonable business necessity to justify differential ages; the Court of Appeals’ reliance on conjecture and gender stereotypes was manifestly mistaken. The Court further held that ratification or receipt of benefits did not bar relief where assent was not free and voluntary and where the provision contravenes law and public policy.
Doctrine:
- A provision of a Collective Bargaining Agreement that is contrary to law, morals, good customs, public order, or public policy is void (Civil Code, arts. 1306 and 1409).
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