Case Digest (G.R. No. 184603)
Facts:
The case revolves around the dispute involving Philippine Airlines, Inc. (PAL) as the Petitioner and Arjan T. Hassaram as the Respondent. It was decided by the Supreme Court on June 5, 2017. Hassaram, a former pilot with a service record of 24 years at PAL, filed a complaint against the airline for illegal dismissal, payment of retirement benefits, damages, and attorney’s fees. In August 2000, Hassaram applied for retirement; however, PAL denied his request, asserting that he had lost his employment because he failed to comply with a Return to Work Order issued by the Secretary of Labor on June 7, 1998, in connection to an industry-wide strike by members of the Airline Pilots Association of the Philippines (ALPAP). Hassaram argued he was not covered by the said order since he was already on his way to work at Eva Air in Taipei on June 9, 1998, under a contract that allowed him to be on leave without pay while working elsewhere, yet accruing seniority with PAL.
The Labor Arbite
...
Case Digest (G.R. No. 184603)
Facts:
Arjan T. Hassaram, a former pilot of Philippine Airlines (PAL), initiated an action against his former employer alleging illegal dismissal and seeking retirement benefits along with damages and attorney’s fees. Hassaram claimed that after 24 years of service he had applied for retirement—but his application was denied because PAL terminated his employment on 9 June 1998 due to his alleged failure to comply with a Return to Work Order issued by the Secretary of Labor. Hassaram contended that at the time of the Order he was already on leave and even en route to report for work at Eva Air under a four-year contract approved by PAL. Meanwhile, PAL argued that Hassaram’s dismissal was valid as it was connected with a broader labor dispute, and further maintained that any retirement benefits were limited to those provided under the company’s collective bargaining agreement (CBA) with the Airline Pilots Association of the Philippines (ALPAP). Initially, the Labor Arbiter (LA) ruled in favor of Hassaram by awarding him retirement benefits computed under Article 287 of the Labor Code, considering that such statutory benefits were superior to those provided by the PAL-ALPAP CBA. PAL then appealed the LA’s ruling to the National Labor Relations Commission (NLRC). During the NLRC proceedings, PAL introduced evidence that Hassaram had already received P4,456,817.75 under the PAL Pilots’ Retirement Benefit Plan (the Plan). Based on this payment, the NLRC reversed the LA’s decision by holding that the benefits already received extinguished any claim for additional retirement pay. However, upon Hassaram’s elevation of the case to the Court of Appeals (CA), the appellate court reversed the NLRC’s reversal. The CA held that the sum received under the Plan was not the retirement pay contemplated by law but, rather, part of a separate benefit scheme. Before this Court, PAL’s sole contention was that Hassaram’s retirement benefits should be computed based solely on the retirement plans provided by PAL rather than on Article 287 of the Labor Code.Issues:
- Whether the amount received by Hassaram under the PAL Pilots’ Retirement Benefit Plan should be considered part of his retirement pay.
- Whether retirement pay for Hassaram should be computed under the statutory scheme provided by Article 287 of the Labor Code or should instead be determined according to the retirement benefit plans established by PAL and the associated CBA.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)