G.R. No. 200088 - Philippine Airlines, Inc. vs. Airline Pilots Association of the Philippines

Philippine Airlines, Inc. (PAL) and Airline Pilots Association of the Philippines (ALPAP) were involved in a labor dispute.
ALPAP, as the exclusive bargaining agent for PAL’s commercial pilots, filed a notice of strike with the Department of Labor and Employment (DOLE) on December 9, 1997, alleging unfair labor practice by PAL.
The Secretary of DOLE assumed jurisdiction over the dispute on December 23, 1997, and subsequently prohibited ALPAP from staging a strike or engaging in acts that might worsen the dispute.

Despite the SOLE’s prohibition, ALPAP staged an illegal strike on June 5, 1998.
The SOLE issued a return-to-work order on June 7, 1998, which was defied by the union, leading to continued strike action.
On June 1, 1999, the SOLE issued a resolution declaring the strike illegal and imposed the loss of employment status on the striking officers.
This resolution was later upheld by the Court of Appeals (CA) in a decision resolved in CA-G.R. SP No. 54880.

On April 22, 2003, almost eight (8) months after the finality of a previous Court resolution, PAL filed a complaint for damages before the Labor Arbiter (LA).

The complaint asserted that on the second day of the illegal strike (June 6, 1998), striking pilots deliberately abandoned three PAL aircraft en route to various international destinations.
PAL alleged that this abandonment stranded passengers, violated its contract of carriage, and incurred substantial expenses (including hotel accommodations, meals, airport fees, and operational losses).

PAL claimed actual damages amounting to P731,078,988.59, and additionally prayed for exemplary damages of P300,000,000.00 and attorney’s fees of P3,000,000.00.

The Labor Arbiter dismissed PAL’s complaint on April 22, 2008, ruling a lack of jurisdiction because:

The SOLE did not certify the dispute for compulsory arbitration under the NLRC, nor did the parties agree on voluntary arbitration under Article 263(h) of the Labor Code.
The complaint was filed beyond the three-year prescriptive period (with prescription calculated from either June 5 or June 7, 1998).
The LA suggested that the claim might be instituted as a separate civil action in another forum.

The NLRC, in a resolution dated April 27, 2009, affirmed with a modification the LA’s decision, emphasizing that:

Labor tribunals had no jurisdiction over PAL’s claims which allegedly arose from tortious acts that are civil in nature.
Claims for damages based on breach of contractual obligation (arising from the strike) required resolution by the regular courts.

A petition for certiorari under Rule 65 before the CA challenging the NLRC’s interpretation.
The CA’s decision on August 26, 2011, which partially granted PAL’s petition by declaring that the NLRC erred in deeming the damage claim as having prescribed while still agreeing that exclusive jurisdiction over claims for damages lies with the regular courts.

PAL’s motion for reconsideration by the CA dated January 5, 2012 was denied, which set the stage for the present petition.

Whether the National Labor Relations Commission (NLRC) and the Labor Arbiter have jurisdiction over PAL’s claims for damages incurred as a consequence of respondents’ actions during the illegal strike.
Whether the claimed damages are “intrinsically intertwined” with the labor dispute, thereby falling within the ambit of labor relations and the SOLE’s assumed jurisdiction.

Whether there is a reasonable causal connection between the alleged unfair labor practices and the damages claimed by PAL.
Whether PAL’s delay in asserting its claim for damages (filing the complaint on April 22, 2003) constitutes a waiver or prejudice to its recovery due to the doctrine of immutability of final judgment.

Whether allowing the claim for damages to be heard by the regular courts instead of by labor tribunals would result in an impermissible splitting of jurisdiction over a labor dispute.