Case Digest (G.R. No. 200088)
Facts:
This is Philippine Airlines, Inc. v. Airline Pilots Association of the Philippines, G.R. No. 200088, February 26, 2018, Supreme Court Third Division, Martires, J., writing for the Court. Petitioner is Philippine Airlines, Inc. (PAL); respondents are Airline Pilots Association of the Philippines (ALPAP) and several of its officers and members.The dispute began when ALPAP, claiming unfair labor practice, filed a notice of strike with DOLE on December 9, 1997. On December 23, 1997 the Secretary of Labor and Employment (SOLE) assumed jurisdiction and prohibited a strike. ALPAP nevertheless staged a strike on June 5, 1998; a SOLE return-to-work order followed on June 7, 1998, which ALPAP defied. On June 1, 1999 the SOLE issued a resolution declaring the strike illegal and declaring loss of employment status of officers who participated. The SOLE resolution was upheld by the Court of Appeals (CA) and this Court dismissed ALPAP’s petition on April 10, 2002; that resolution attained finality on August 29, 2002.
On April 22, 2003, PAL filed before the Labor Arbiter (LA) a complaint for damages against ALPAP and certain officers and members, alleging that striking pilots abandoned three international flights on June 6, 1998, stranding passengers and causing extensive operational losses and expenses; PAL claimed actual damages of P731,078,988.59 plus exemplary damages and attorney’s fees. On April 22, 2008 the LA dismissed PAL’s complaint — ruling it lacked jurisdiction because the SOLE had not certified the controversy for arbitration and thus the SOLE retained exclusive jurisdiction under Article 263(h) (now identified in dicta with other provisions), and alternatively finding the claim prescribed under Article 291 of the Labor Code. The dispositive ordered dismissal for lack of merit.
PAL appealed to the National Labor Relations Commission (NLRC). In a resolution dated April 27, 2009, the NLRC affirmed the LA’s dismissal but modified the dispositive phrase “for lack of merit” (reasoning that regular courts, not labor tribunals, have jurisdiction over tort-like claims). NLRC denied reconsideration on February 26, 2010.
PAL then filed a petition for certiorari under Rule 65 before the CA. On August 26, 2011 the CA partially granted PAL’s petition: it agreed that labor tribunals lacked jurisdiction but held the NLRC gravely abused discretion in ruling the claim had prescribed, concluding that PAL’s cause of action accrued only on August 29, 2002 when this Court’s resolution became final, and therefore the claim had not prescribed. The CA modified the NLRC resolutions to declare (1) the claim lies with the regular courts and (2) P...(Subscriber-Only)
Issues:
- Whether the NLRC and the Labor Arbiter had jurisdiction over PAL’s claims for damages arising from the illegal strike.
- Whether PAL’s claim for damages is barred (by prescription, waiver, or by the immutability of final judgment) so as to preclude recovery after the SOLE and the courts finalized t...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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