Case Digest (G.R. No. 85985) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine Airlines, Inc. (PAL) v. National Labor Relations Commission and Philippine Airlines Employees Association (PALEA) (G.R. No. 85985, August 13, 1993), PAL on March 15, 1985 unilaterally revised its 1966 Code of Discipline, circulated it in limited copies and immediately enforced its sanctions. On August 20, 1985, PALEA filed an unfair labor practice (ULP) complaint before the NLRC (Case No. NCR-7-2051-85) alleging arbitrary implementation without notice or prior discussion, violation of Articles 249(E) and 253 of the Labor Code, and sought to enjoin enforcement, reinstate dismissed employees, and declare damages. PAL moved to dismiss, invoking its managerial prerogative to promulgate rules and contending no breach of the collective bargaining agreement (CBA) or the Labor Code. Labor Arbiter Isabel P. Ortiguerra, after deeming the parties’ absence as waiver of evidence, issued a decision (November 7, 1986) finding no bad faith but faulting sections for overbreadth, do Case Digest (G.R. No. 85985) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Revision and Implementation of the Code of Discipline
- On March 15, 1985, Philippine Airlines, Inc. (PAL) completely revised its 1966 Code of Discipline, circulated limited copies among employees, and immediately implemented disciplinary measures thereunder.
- Some employees were disciplined under the new Code without prior discussion with the union.
- PALEA’s Unfair Labor Practice (ULP) Complaint
- On August 20, 1985, the Philippine Airlines Employees Association (PALEA) filed ULP Case No. NCR-7-2051-85 before the National Labor Relations Commission (NLRC), alleging arbitrary implementation of the Code without notice or discussion, in violation of Articles 249(E), 249(G), and 253 of the Labor Code.
- PALEA prayed for:
- Suspension of the Code’s implementation;
- Discussion of the Code’s substance with PALEA;
- Reinstatement and further hearing of disciplined employees; and
- Declaration of unfair labor practice with damages.
- Labor Arbiter Proceedings
- PAL moved to dismiss, asserting its management prerogative to prescribe employee rules and no CBA or Labor Code violation.
- PALEA, in reply, challenged Sections 2 (Non-exclusivity) and 7 (Cumulative Record) of the Code as overbroad and punitive.
- The labor arbiter declared the case submitted for decision after both parties failed to appear at the conference.
- On November 7, 1986, the arbiter found no ULP but held certain Code provisions unreasonable and ordered PAL to:
- Furnish all employees with the new Code;
- Reconsider and remand disciplined cases for further hearing; and
- Discuss the Code’s objectionable provisions with PALEA.
- NLRC Decision
- On August 19, 1988, the NLRC affirmed the dismissal of the ULP charge but observed that management should not exclude labor in adopting rules affecting employment and property rights.
- It modified the arbiter’s orders, directing PAL to:
- Review and discuss the Code with PALEA;
- Furnish each employee a copy of the Code; and
- Reconsider pending disciplinary cases.
- Petition for Certiorari
- PAL filed this petition, alleging grave abuse of discretion by public respondents in:
- Compelling PAL to share its management prerogative in formulating the Code;
- Engaging in quasi-judicial legislation;
- Deciding beyond the ULP issue; and
- Ordering reconsideration of pending cases.
Issues:
- Whether the formulation of a Code of Discipline is a shared responsibility requiring management to involve the union or employees.
- Whether the NLRC gravely abused its discretion by ordering PAL to share its management prerogative, legislate quasi-judicially, decide beyond the ULP issue, and require reconsideration of pending cases.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)