Case Digest (G.R. No. 186045)
Facts:
Philippine Airlines, Inc. v. Airline Pilots Association of the Philippines, G.R. No. 143686, January 15, 2002, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.Petitioner Philippine Airlines, Inc. (PAL) unilaterally retired Captain Albino Collantes pursuant to Section 2, Article VII of the 1967 PAL‑ALPAP Retirement Plan. Respondent Airline Pilots Association of the Philippines (ALPAP), the exclusive bargaining representative of PAL pilots, claimed the retirement was an illegal dismissal and constituted union‑busting, and filed a Notice of Strike with the Department of Labor and Employment (DOLE). Relying on Article 263(g) of the Labor Code, the Secretary of Labor assumed jurisdiction over the dispute.
On June 13, 1998 the Secretary issued an order that (a) recognized PAL’s retirement of Captain Collantes as a valid exercise of its option under Sections 1 and 2, Article VII of the 1967 Retirement Plan but (b) directed that computation of retirement benefits should follow Article 287 of the Labor Code (as amended by Republic Act No. 7641) rather than Section 2 of the 1967 Plan; and (c) added a requirement that PAL must consult the pilot before implementing retirement. A motion for reconsideration of that order was, according to the record, denied on June 1, 1991.
PAL sought relief in the Court of Appeals by filing a petition for certiorari with prayer for injunction and a temporary restraining order on September 24, 1999. The Court of Appeals denied the petition in its March 2, 2000 Decision and likewise denied PAL’s motion for reconsideration in its June 19, 2000 Resolution, applying the second paragraph of Article 287 to hold that retirement benefits under any collective bargaining agreement shall not be less than those provided in the Labor Code.
PAL elevated the case to the Supreme Court by a petition for review on certiorari seeking annulment and setting aside of the Court of Appeals’ March 2, 2000 Decision and June 19, 2000 Resolution. PAL argued, inter alia, that (I) the Secretary exceeded the scope of issues in NCMB proceedings by increasing retirement pay, (II) the Secretary’s order denied due process, (III) contracting parties have exclusive right to determine CBA terms, (IV) the Secretary’s amendment of the CBA violated the prohibition against impairment of contracts, (V) it was improper to compel PAL to pay under Article 287, and (VI) it was improper to compel PAL to consult the pilot before retirement. The 1...(Subscriber-Only)
Issues:
- Did the Secretary of Labor deprive PAL of due process or exceed his authority by imposing an additional requirement (consultation of the pilot) not raised in the NCMB proceeding?
- Should Captain Collantes’ retirement benefits be computed under Article 287 of the Labor Code (as amended by RA 7641) or under the 1967 PAL‑ALPAP Retirement Plan (and the separate PAL Pilots Retirement Benefit Plan)?
- Was the Secretary’s directive that PAL consult the pilot before exercising its option to retire him a valid regulation of management prerogative, or did it unlawfully amend the CBA and confer an undue prerogative on the employee?
- Was PAL guilty of gross ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)