Case Digest (G.R. No. 110656)
Facts:
In Philippine Airlines, Inc. v. National Labor Relations Commission, G.R. No. 110656, September 03, 1998, the Supreme Court Third Division, Purisima, J., writing for the Court, resolved a Rule 65 petition for certiorari seeking to annul the NLRC First Division Decision of May 19, 1993 (pened by Commissioner Vicente S.E. Veloso, with Commissioners Bartolome S. Carale and Alberto R. Quimpo, concurring).The private respondents (a group of rank-and-file employees represented by Philippine Airlines Employees Association (PALEA)) were hired in 1987 by Philippine Air Lines, Inc. (PAL) as Junior Aircraft Mechanics at a monthly basic salary of P1,860.00. Effective October 1, 1987, they received a P400.00 CBA wage increase, making the monthly pay P2,260.00. After the enactment of Republic Act No. 6640 on December 14, 1987, their salaries were adjusted to reflect an additional P304.00 mandated increase, yielding P2,564.00.
In June 1988 the employees were promoted to Avionics Mechanic C with a new basic pay of P2,300.00 plus the P400.00 CBA increase, giving a gross monthly pay of P2,700.00. The employees asserted that the P304.00 under RA 6640 should still be integrated into their compensation after promotion, making their gross pay P3,004.00; PAL treated the P440.00 difference between the new and old basic salaries as sufficient compliance with RA 6640 (allocating P304.00 to the statutory increase and P136.00 as promotional increment).
Unable to reconcile the dispute, the employees filed NLRC-NCR Case No. 00-12-05086-88. On November 29, 1989, Labor Arbiter Cornelio L. Linsangan ordered PAL to integrate P304.00 into the monthly salary of the affected employees, pay salary differentials with legal interest, and awarded 10% attorneys’ fees; other claims were dismissed. PAL appealed to the National Labor Relations Commission (NLRC), which dismissed the appeal for lack of merit, affirming that the repeated grant of a statutory wage increase vests a right in employees and that RA 6640’s increases were not intended as temporary nor intended to be offset by promotions.
PAL then filed a Petition for Certiorari under Rule 65 in the Supreme Court, raising two questions: (1) whether RA 6640 was meant to g...(Pro-only)
Issues:
- Was PAL entitled to treat promotional salary increases as creditable against the statutory wage increase under RA 6640 — i.e., was the RA 6640 wage increase non-permanent/offsettable upon promotion?
- Did the NLRC gravely abuse its discretion in stating it had no jurisdiction to resolve the ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)