Case Digest (G.R. No. 118463)
Facts:
Philippine Airlines, Inc. v. National Labor Relations Commission and Philippine Airlines Employees Association (PALEA), G.R. No. 118463, December 15, 1997, Supreme Court Third Division, Narvasa, C.J., writing for the Court.The dispute began with a written extension of the 1977 collective bargaining agreement (CBA) between Philippine Airlines, Inc. (PAL) and Philippine Airlines Employees Association (PALEA) executed on February 23, 1979, which extended the CBA to September 30, 1980 and committed PAL to implement a Job Evaluation Program (JEP) to produce a new payscale effective November 1, 1978. PAL implemented a new payscale, and subsequently a series of Presidential Decrees and Wage Orders (PDs 1614, 1713, 1751 and successive Wage Orders Nos. 1–6) raised minimum wages and emergency living allowances between 1979 and 1985.
PAL and PALEA negotiated a new CBA covering October 1, 1980 to September 30, 1983, signed May 18, 1981, which provided across-the-board increases and a revision of the payscale effective October 1, 1982. Implementation of that revised payscale was disputed: PALEA complained that PAL failed to consult the union as agreed and that the updated payscale produced wage distortions relative to statutory minimums. Further CBA negotiation yielded a new CBA on September 14, 1984 covering 1983–1986 with across-the-board increases and seniority pay intended to preserve wage gaps.
On December 29, 1983 PALEA filed a complaint with the Labor Arbiter (docketed NLRC Case No. 12-5704-83) alleging (1) unfair labor practice for failure to consult on implementation of the payscale and (2) violation of Wage Orders Nos. 2 and 3 for failing to cure wage distortions. The case was held in abeyance during later CBA negotiations but was resumed with supplemental complaints alleging violations of additional Wage Orders (Nos. 1, 4, 5 and 6). PAL denied the allegations, claimed it had consulted and remedied distortions via the 1983–1986 CBA, and pointed to a mutual waiver clause in that CBA.
Labor Arbiter Teodorico Ruiz, by Order dated April 28, 1986, found that wage distortions existed, ordered the parties to meet within five days to discuss correcting the distortions and directed the NLRC Socio-Economic Analyst to compute amounts due, and awarded attorney’s fees. The NLRC En Banc affirmed the Labor Arbiter on November 2, 1988 but revised the dispositive portion to clarify that the parties must meet first and thereafter the Socio-Economic Analyst would compute the amounts. PAL filed a motion for reconsideration on November 21, 1988 which was denied by the NLRC on September 30, 1994.
PAL filed a petition for certiorari challenging the NLRC resolution (petition filed January 16, 1995). The Court treated the petition under Rule 45, required memoranda, and received submissions from PAL, PALEA and the Solicitor General. PAL’s principal contentions were that (a) the Labor Arbiter and NLRC lacked jurisdiction to adjudicate wage distortion claims (which should be resolved under CBA grievance machinery or voluntary arbitration) and (b) the NLRC gravely abused its discretion in finding wage distortion when none existed. PALEA and the Solicitor General defended the NLRC’s rulings and argued that the NLRC properly exercised jurisdiction and that wage distortions did exist.
The Supreme Court considered the impact of Republic Act No. 6715 (effective March 21, 1989), which shifted jurisdiction over interpretation or implementation of CBAs to voluntary arbitrators (Article 261, Labor Code as amended), and precedents on t...(Subscriber-Only)
Issues:
- Did the Labor Arbiter and the National Labor Relations Commission have jurisdiction to hear and decide PALEA’s complaint given the subsequent enactment of Republic Act No. 6715 (amending the Labor Code)?
- Did the NLRC gravely abuse its discretion in declaring the existence of a wage distortion and orde...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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