G.R. No. 88210 - Philippine Airlines, Inc. vs. Secretary of Department of Labor and Employment

Philippine Airlines, Inc. (PAL), the petitioner, and the Philippine Airlines Employees Association (PALEA), the respondent union, entered into a Collective Bargaining Agreement (CBA) for 1986-1989.
The CBA included provisions on pay increases and the creation of a PAL/PALEA Payscale Panel tasked with reviewing and updating job classifications and payscales.
The Payscale Panel was to conclude its studies and propose updated payscales by January 1, 1988.

By July 1988, the Job Evaluation Committee finished initial evaluation and reconciliation of positions.
The PALEA panel members proposed a minimum salary entry level of PHP 3,349 for the lowest job classification (Job Grade 1).
The PAL panel members countered with PHP 2,310 and a PHP 200 across-the-board increase for employees not covered by the payscale adjustments.
Deadlock ensued as PALEA refused anything less than their proposal, while PAL claimed it had no authority to offer higher amounts.
PALEA accused PAL of bargaining in bad faith.

On December 29, 1988, PALEA filed a strike notice with the National Conciliation and Mediation Board (NCMB) citing bargaining deadlock and unfair labor practice.
PAL moved to dismiss the strike notice on the ground of prematurity, as the existing CBA had nine months left until expiration (September 30, 1989).
The NCMB treated the strike notice as appropriate only for preventive mediation and not lawful grounds for strike.
Despite this, NCMB representatives supervised a PALEA strike vote, confusing PAL's counsel who sought clarification.

After the strike vote, PALEA declared a strike on January 20, 1989, which paralyzed PAL operations starting January 21, causing massive disruptions and financial losses.
On January 13, 1989, PAL petitioned Secretary of Labor Franklin Drilon to assume jurisdiction to avert the strike, highlighting PAL’s government equity, national interest, and economic consequences.
Secretary Drilon delayed acting for seven days and only issued an order on January 20, 1989, after the strike had begun.
The Secretary assumed jurisdiction, ordered the strike lifted, workers reinstated, prohibited retaliatory actions by PAL, and granted monetary benefits to the union members involved.
Secretary Drilon declared the strike valid despite PALEA’s notice initially treated as preventive mediation by NCMB.
PAL filed a motion for reconsideration, denied three months later.

Whether the Secretary of Labor had jurisdiction to rule on the legality of the PALEA strike.
Whether the Secretary of Labor exceeded his authority in prohibiting PAL from taking retaliatory or disciplinary actions against union officers and members participating in the strike.
Whether the Secretary of Labor erred in failing to promptly assume jurisdiction to prevent the damage caused by the strike.