Title
Castells vs. Saudi Arabian Airlines
Case
G.R. No. 188514
Decision Date
Aug 28, 2013
Flight attendants alleged forced resignation after transfer to Jeddah; Supreme Court ruled CA erred in rejecting petition, remanding for merits review.
A

Case Summary (G.R. No. 188514)

Facts of the Case

On August 24, 2004, Saudi Arabian Airlines issued a memo ordering the transfer of 10 flight attendants, including the petitioners, from Manila to Jeddah, Saudi Arabia, citing "operational requirements." While Centi-Mandanas complied with the transfer, Castells did not. Centi-Mandanas claimed that upon arrival in Jeddah, she was informed her contract would not be renewed and was requested to sign a pre-typed resignation letter, which she reluctantly did. Castells, who did not comply with the transfer order, alleged that she was coerced into resigning under duress after being instructed to amend her resignation letter to reflect that it was voluntary.

Legal Proceedings Initiated by Petitioners

In response to their treatment, Castells and Centi-Mandanas, along with a co-flight attendant, filed a complaint for illegal dismissal against Saudi Arabian Airlines, seeking reinstatement, back wages, moral damages, and attorney's fees. They contended that the airline intended to dismiss them due to their age, as evidenced by the circumstances surrounding their transfer.

Defense of Respondent

In its defense, Saudi Arabian Airlines claimed that the petitioners’ resignations were voluntary and appropriately executed, evidenced by signed resignation letters and an undertaking in which they acknowledged receiving compensation and released the airline from further claims.

Labor Arbiter's Ruling

On August 31, 2006, the Labor Arbiter ruled in favor of the petitioners, finding that their resignations were not made voluntarily but were a result of coercion by the airline. The Labor Arbiter ordered the airline to pay full back wages and separation pay for each petitioner, less any amounts already received.

National Labor Relations Commission Ruling

The airline appealed this decision to the National Labor Relations Commission (NLRC), which on June 25, 2007, reversed the Labor Arbiter's ruling. The NLRC cited the language of gratitude within the resignation letters and upheld the validity of their resignation and release undertaking, asserting that the petitioners, being educated individuals, could not be coerced into signing documents without understanding them.

Court of Appeals Proceedings

Petitioners subsequently filed a motion with the Court of Appeals (CA) for an extension to file a petition for certiorari. The CA initially granted this request but later reconsidered and reversed its earlier resolution, stating the petition was not due to compliance with procedural time limits resulting from a new administrative matter that restricted extensions for such petitions.

Supreme Court's Ruling on Appeal

Before the Supreme Court, the central issue was whethe

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