Case Digest (G.R. No. 172013) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Patricia Halagueaa et al. v. Philippine Airlines, Inc. (G.R. No. 172013, October 2, 2009), the petitioners are female flight attendants of Philippine Airlines (PAL) employed before November 22, 1996 and members of the Flight Attendants and Stewards Association of the Philippines (FASAP), the exclusive bargaining representative. PAL and FASAP executed a Collective Bargaining Agreement (CBA) for 2000–2005, which, under Section 144, Part A, prescribed a compulsory retirement age of 55 for females and 60 for males. On July 22, 2003, petitioners formally protested this gender‐based differentiation as discriminatory and reiterated the demand during the 2004–2005 negotiation proposals. On July 29, 2004, they filed a Special Civil Action for Declaratory Relief with a Prayer for Temporary Restraining Order (TRO) and Writ of Preliminary Injunction in RTC Makati, Branch 147 (Civil Case No. 04-886), challenging the validity of the compulsory retirement provision. The RTC assumed jurisdic Case Digest (G.R. No. 172013) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Collective Bargaining Agreement (CBA)
- Petitioners are female flight attendants of Philippine Airlines (PAL), members of FASAP, the certified bargaining representative.
- Respondent is Philippine Airlines, Inc.
- Discriminatory Provision and Pre-litigation Steps
- The PAL-FASAP CBA (2000–2005), Section 144, Part A, set compulsory retirement at age 55 for females and 60 for males (for those hired before November 22, 1996).
- In July 2003 and July 2004, petitioners and FASAP wrote to PAL demanding removal of the gender-based retirement age difference. FASAP submitted renegotiation proposals but no agreement was reached.
- Procedural History
- RTC of Makati (Branch 147)
- July 29, 2004 – Petitioners filed a special civil action for declaratory relief with TRO and preliminary injunction to enjoin Section 144, Part A.
- August 9, 2004 – RTC upheld its jurisdiction; August 10, 2004 – issued TRO; September 27, 2004 – granted preliminary injunction.
- Court of Appeals (CA)
- October 8, 2004 – PAL filed certiorari seeking to annul RTC’s jurisdictional orders and lift the TRO.
- August 31, 2005 – CA held RTC had no jurisdiction and dismissed Civil Case No. 04-886; March 7, 2006 – denied motion for reconsideration.
- Supreme Court
- Petition for review under Rule 45 filed by petitioners to reverse CA’s decision and resolution.
Issues:
- Jurisdictional Question
- Whether petitioners’ challenge to the compulsory retirement age provision in the CBA is a labor dispute exclusively within the jurisdiction of labor tribunals (labor arbiter/NLRC).
- Whether the Regional Trial Court, as a court of general jurisdiction, may adjudicate a civil action for declaratory relief on the legality and constitutionality of a CBA provision not involving pecuniary estimation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)