Case Summary (G.R. No. 197849)
Petitioner and Respondent
Petitioners: Patricia Halagueaa, Ma. Angelita L. Pulido, Ma. Teresita P. Santiago, Marianne V. Katindig, Bernadette A. Cabalquinto, Lorna B. Tugas, Mary Christine A. Villarete, Cynthia A. Stehmeier, Rose Anna G. Victa, Noemi R. Cresencio, and other similarly situated female flight attendants of PAL.
Respondent: Philippine Airlines, Incorporated.
Key Dates
• November 22, 1996 – Cutoff date for determining which cabin attendants are covered by the disputed retirement provision.
• July 11, 2001 – PAL and FASAP executed the 2000–2005 CBA incorporating Section 144, Part A.
• July 22, 2003 – Petitioners formally protested the gender-based compulsory retirement ages.
• July 29, 2004 – Petitioners filed a petition for declaratory relief, seeking to nullify the discriminatory provision.
• August 10, 2004 – Regional Trial Court (RTC) of Makati City issued a temporary restraining order enjoining enforcement of Section 144, Part A.
• September 27, 2004 – RTC issued a writ of preliminary injunction.
• October 8, 2004 – PAL filed a petition for certiorari and prohibition in the Court of Appeals (CA).
• August 31, 2005 – CA rendered the decision annulling the RTC’s jurisdiction.
• March 7, 2006 – CA denied petitioners’ motion for reconsideration.
• October 2, 2009 – Supreme Court decision on petition for review under Rule 45.
Applicable Law
• 1987 Philippine Constitution (Section 14, Article II – equality before the law).
• Labor Code of the Philippines (P.D. No. 442 as amended).
• Republic Act No. 6725 (strengthening prohibition on discrimination against women).
• Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW).
• Batas Pambansa Blg. 129, Section 19 – exclusive original jurisdiction of RTC in civil actions incapable of pecuniary estimation.
• Civil Code provisions on contracts and public policy (Article 1306; Article 1700).
Factual Background
PAL and FASAP negotiated the 2000–2005 CBA, which included a compulsory retirement clause setting retirement at age fifty-five for females and sixty for males among cabin attendants hired before November 22, 1996. Petitioners contended that this gender-based differentiation violated constitutional equality guarantees, the Labor Code’s prohibition against sex discrimination, RA 6725, and CEDAW. They demanded removal of the discriminatory clause in forthcoming CBA negotiations.
Procedural History
Petitioners filed a special civil action for declaratory relief in the RTC of Makati City, Branch 147, seeking to nullify Section 144, Part A of the CBA and obtained both a TRO and a writ of preliminary injunction enjoining its enforcement. PAL challenged the RTC’s jurisdiction by filing a petition for certiorari and prohibition before the CA, which granted relief and dismissed the civil case for lack of jurisdiction. Petitioners sought review under Rule 45 before the Supreme Court.
Issue Presented
Whether the RTC has original and exclusive jurisdiction to entertain a civil action for declaratory relief challenging the legality and constitutionality of a CBA provision on compulsory retirement age, or whether the matter is exclusively within the purview of labor tribunals and grievance/arbitration machinery.
Petitioners’ Position
Petitioners argued that their cause of action is the annulment of a provision in the CBA on grounds of unconstitutionality and illegality, raising questions of fundamental equality and public policy that cannot be resolved exclusively by reference to the Labor Code. The subject matter is incapable of pecuniary estimation, falling squarely within the RTC’s civil jurisdiction under Batas Pambansa Blg. 129, Section 19. They maintained that labor arbiters and the National Labor Relations Commission (NLRC) lack competence to decide constitutional issues or interpret treaties such as CEDAW.
Respondent’s Position
PAL contended that the controversy concerns terms and conditions of employment under a CBA and therefore constitutes a labor dispute within the exclusive jurisdiction of voluntary arbitrators and labor tribunals. PAL asserted that regular courts have no power to alter or nullify CBA provisions and that petitioners’ remedy lies before the grievance machinery and the NLRC.
Supreme Court’s Analysis on Jurisdiction
The Court held that jurisdiction is determined by the nature of the relief sought and the character of the action. Petitioners do not seek enforcement of rights under the CBA but the annulment of its retirement clause on constitutional and statutory grounds. Such relief cannot be granted by labor tribunals, whose jurisdiction is confined to disputes resolvable by application of the Labor Code, other labor statutes, or the CBA itself.
Regular Courts versus Labor Tribunals
Citing established jurisprudence, the Court explained that labor arbiters and the NLRC resolve employer-employee controversies arising directly under labor laws or collective agreements. When the cause of action stems from general civil law, constitutional provisions, or international treaties, the dispute transcends labor management
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Facts
- Petitioners are female flight attendants of Philippine Airlines (PAL) employed before November 22, 1996 and members of FASAP, the certified bargaining representative.
- On July 11, 2001, PAL and FASAP entered into a Collective Bargaining Agreement (PAL-FASAP CBA) for 2000–2005.
- Section 144, Part A of the CBA provided compulsory retirement at age 55 for females and age 60 for males, subject to grooming standards.
- On July 22, 2003, petitioners and other female cabin crews protested this gender-based distinction as discriminatory; counsel reiterated the demand for equal treatment in renegotiations.
- FASAP submitted 2004–2005 CBA proposals on July 12, 2004, including willingness to start bargaining as soon as possible.
Procedural History
- July 29, 2004: Petitioners filed a Special Civil Action for Declaratory Relief with Prayer for TRO and Preliminary Injunction (RTC Makati, Branch 147, Civil Case No. 04-886) seeking invalidation of Section 144, Part A.
- August 9, 2004: RTC issued order asserting jurisdiction over the declaratory relief action.
- August 10, 2004: RTC granted TRO enjoining implementation of the retirement provision.
- September 27, 2004: RTC issued Preliminary Injunction pending resolution on the merits.
- October 8, 2004: PAL filed petition for certiorari and prohibition with prayer for TRO and preliminary injunction before the Court of Appeals (CA-G.R. SP No. 86813) to annul RTC’s jurisdictional rulings.
- August 31, 2005: CA Decision granted PAL’s petition, declared RTC had no jurisdiction, annulled all proceedings, and ordered dismissal of Civil Case No. 04-886.
- March 7, 2006: CA denied petitioners’ motion for reconsideration.
- October 2, 2009: Petition for review under Rule 45 filed with the Supreme Court.
Issues
- Whether the Regional Trial Court has jurisdiction over a petition for d