Case Digest (G.R. No. 114776)
Facts:
In Menandro B. Laureano vs. Court of Appeals and Singapore Airlines Limited (G.R. No. 114776, February 2, 2000), petitioner Menandro B. Laureano, then Director of Flight Operations and Chief Pilot of Air Manila, applied in 1978 for a captain’s post with Singapore Airlines through its Manila office. An expatriate B-707 captain contract was offered on September 30, 1978 for two years beginning January 21, 1979, later extended to five years (to January 20, 1984). During his tenure, Laureano committed a noise violation at Zurich Airport on August 24, 1980 and was reprimanded for a tail scrape incident. In 1981 he completed A-300 conversion training in France and served as A-300 captain. In 1982, amid a global airline recession, the company identified surplus Airbus pilots; Laureano was not selected for B-747 promotion and was notified on October 5, 1982 of his termination effective November 1, 1982, with two months’ notice and one month’s salary in lieu of notice. Laureano first filCase Digest (G.R. No. 114776)
Facts:
- Employment Engagement and Confirmation
- Menandro B. Laureano applied in 1978 for a B-707 expatriate captain position with Singapore Airlines through its Manila Area Manager; offered a two-year contract (Jan. 21, 1979–Jan. 20, 1981), which he accepted and commenced work on January 20, 1979.
- After passing a six-month probation, his appointment was confirmed July 21, 1979, and his contract was extended to five years (Jan. 21, 1979–Jan. 20, 1984).
- In-Service Incidents and Career Progression
- On August 24, 1980, while commanding a flight at Zurich Airport, Laureano committed a noise violation and later apologized; he was also involved in a tail-scraping runway incident, suspended briefly, investigated, and reprimanded.
- He underwent Airbus A-300 conversion training in Toulouse, France (invited Sept. 25, 1981), passed, and was appointed A-300 captain effective April 7, 1981, flying Southeast Asia routes.
- Retrenchment, Termination, and Litigation
- In 1982, amid global recession, Singapore Airlines found 17 expatriate A-300 captains in excess; after reviewing promotion eligibility, Laureano was not selected and was informed on October 5, 1982 of termination effective November 1, 1982, with two months’ notice and one month’s pay in lieu of three-month notice.
- Laureano filed for illegal dismissal before the Labor Arbiter on June 29, 1983, withdrew the complaint, then on January 8, 1987 filed a civil suit for damages in the Regional Trial Court (RTC) of Manila. The RTC denied respondent’s motion to dismiss and rendered judgment for Laureano on April 10, 1991. Singapore Airlines appealed to the Court of Appeals (CA), which reversed on prescription grounds (action filed over four years after dismissal) in a decision dated October 29, 1993; motions for reconsideration were denied. Laureano then petitioned the Supreme Court.
Issues:
- Prescription Period
- Whether Laureano’s action is grounded on a written contract (10-year prescription under Civil Code Art. 1144) or on damages for injury to rights (4-year prescription under Civil Code Art. 1146) or on money claims under the Labor Code (3-year prescription under Lab. Code Art. 291).
- Validity of Retrenchment and Termination
- Whether an employee with a fixed-term contract may be validly retrenched.
- Whether expected but unrealized profits suffice as a basis for retrenchment under the contract.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)