Case Summary (A.M. No. MTJ-02-1433)
Background of the Labor Dispute
The dispute escalated when ALPAP filed a notice of strike on December 9, 1997, citing unfair labor practices and union-busting by PAL. On December 23, 1997, the Secretary of the Department of Labor and Employment (DOLE) assumed jurisdiction over the labor conflict. A strike was declared on June 5, 1998, despite ongoing negotiations. A return-to-work order was issued on June 7, 1998, mandating all striking personnel to return by June 9, 1998. However, the strike persisted, and upon attempting to return on June 26, 1998, PAL refused to accept the pilots, stating the deadline had lapsed. This refusal prompted ALPAP to file an illegal lockout case.
Administrative Rulings
On June 1, 1999, the Secretary issued a resolution declaring that all strikers had lost their employment status due to their participation in the illegal strike. This resolution was questioned by ALPAP but was upheld by the Supreme Court in G.R. No. 152306. Subsequently, ALPAP sought clarification regarding which of its members lost their employment status, but this motion was denied.
Review and Initial CA Decision
Petitioners, having been affected by the rulings, initiated their complaints of illegal dismissal and monetary claims against PAL in separate cases. Initially, a Labor Arbiter ruled in their favor on August 25, 2000, but this decision was overturned by the NLRC on the grounds of jurisdiction due to PAL's rehabilitation proceedings. Once rehabilitation was completed, petitions resumed, but the Labor Arbiter ultimately dismissed the case on July 16, 2008, citing the petitioners' involvement in the unlawful strike.
Court of Appeals Rulings
The NLRC affirmed the Labor Arbiter's findings. However, the CA granted certiorari relief to the petitioners, initially ruling that they had been on approved leave during the strike and thus could not be considered as strikers. The issuance of the return-to-work order was interpreted narrowly, and the CA set aside the NLRC decision, ordering the reinstatement of the petitioners and the payment of backwages.
Amended CA Decision and Subsequent Findings
Upon PAL's motion for reconsideration, the CA reversed its initial decision, emphasizing the significance of the return-to-work logbook signed by the pilots on June 26, 1998. It concluded that the pilots’ belated attempt to return implied their participation in the illegal strike. The CA recognized that the actions of the petitioners before and during the strike undermined their claims of not being strikers.
Legal Framework and Principles
In evaluating the presence of grave abuse of discretion, the Supreme Court reiterated the limited scope of review in labor cases under Rule 45. The Court concluded that the CA's amending decision, which affirmed the NLRC's dismiss
...continue readingCase Syllabus (A.M. No. MTJ-02-1433)
Case Overview
- The case involves a petition for review on certiorari under Rule 45 of the Rules of Court filed by petitioners Salvador P. Almagro, Basilio M. Cruz, Francisco M. Juliano, Arturo L. Novenario, and the heirs of Demosthenes V. CaAete against respondents Philippine Airlines, Inc. (PAL), Lucio Tan, and Jose Antonio Garcia.
- The petition aims to nullify the Court of Appeals' (CA) December 7, 2012 Amended Decision, which reversed an earlier ruling favoring petitioners and affirmed the National Labor Relations Commission's (NLRC) dismissal of their complaints.
Background of the Case
- The case originates from a labor dispute in the 1990s involving PAL and the Airline Pilots Association of the Philippines (ALPAP), the exclusive bargaining agent for PAL's commercial pilots.
- On December 9, 1997, ALPAP filed a notice of strike due to alleged unfair labor practices by PAL. The Department of Labor and Employment (DOLE) Secretary assumed jurisdiction over the dispute on December 23, 1997.
- A strike was declared on June 5, 1998, despite the Secretary’s assumption of jurisdiction. A return-to-work order was issued on June 7, 1998, but the strike continued until June 26, 1998.
Key Events Leading to the Dispute
- Employees who attempted to return to work on June 26, 1998, signed the PAL security logbook. However, PAL refused to accept them, citing that the deadline for compliance with the return-to-work order had lapsed.
- In response, ALPAP filed an illegal lockout case against PAL on June 29, 1998, which was consolidated with the strike case.
- The Secretary issued a resolution on June 1, 1999, declaring that all officers and members participating in the strike had lost their employment status and dismissing the illegal lockout case.
Decisions of the Labor Arbiter and NLRC
- On July 16, 2008, the Labor Arbiter dismissed the conso