Title
Halaguena vs. Philippine Airlines, Inc.
Case
G.R. No. 172013
Decision Date
Oct 2, 2009
Female flight attendants challenge discriminatory retirement age in PAL-FASAP CBA, seeking equal treatment; SC rules RTC has jurisdiction, remands case for trial.

Case Summary (G.R. No. 172013)

Key Dates

Collective Bargaining Agreement (PAL–FASAP CBA) covering years 2000–2005 executed July 11, 2001; petitioners’ letters asserting discrimination dated July 22, 2003 and counsel’s demand to remove gender-discriminatory provisions; FASAP’s 2004-2005 proposals submitted July 12, 2004; petition for declaratory relief filed July 29, 2004 in RTC Makati (Civil Case No. 04-886); RTC issued TRO and preliminary injunction in August–September 2004; CA annulled RTC jurisdiction by decision dated August 31, 2005 (resolution denying reconsideration March 7, 2006); Supreme Court decision reversing CA dated October 2, 2009.

Applicable Law and Constitutional Basis

Because the decision date is after 1990, the 1987 Philippine Constitution governs the constitutional analysis. Petitioners invoked Section 14, Article II (equal protection/fundamental equality) of the 1987 Constitution, provisions of the Labor Code (including Article 135 as amended by RA 6725), and the international treaty CEDAW (ratified by the Philippines in 1981). Statutory and jurisprudential principles on the jurisdiction of regular courts versus labor tribunals were central to the analysis.

Contested CBA Provision

Section 144, Part A of the PAL–FASAP CBA established a compulsory retirement age of fifty-five (55) for female cabin attendants hired before November 22, 1996, and sixty (60) for males. Petitioners alleged this differential compulsory retirement age is discriminatory and violative of the Constitution, the Labor Code, and CEDAW.

Procedural History in the Lower Courts

Petitioners filed a special civil action for declaratory relief with prayer for TRO and preliminary injunction in RTC Makati to annul the discriminatory CBA provision. The RTC assumed jurisdiction, issued a TRO and later a preliminary injunction enjoining enforcement of the challenged provision, and required memoranda. PAL filed an omnibus motion questioning RTC jurisdiction and subsequently petitioned the CA for certiorari and prohibition, which the CA granted, declaring the RTC had no jurisdiction and annulling its proceedings. The CA denied petitioners’ motion for reconsideration, prompting review by the Supreme Court.

Issue Presented

Whether the RTC had jurisdiction to entertain petitioners’ declaratory action seeking annulment of the compulsory retirement provision of the CBA, or whether the controversy was exclusively a labor dispute cognizable by labor tribunals (labor arbiter, NLRC) or subject to the CBA’s grievance machinery and voluntary arbitration.

Parties’ Contentions

Petitioners: The action is an ordinary civil action challenging the legality and constitutionality of a CBA provision; it involves rights incapable of pecuniary estimation, raises pure questions of law (constitutional and treaty-based), and therefore belongs to the RTC. They asserted the matter could not be resolved solely by reference to the Labor Code or collective bargaining processes.
Respondent (PAL): The subject involves terms and conditions of employment (retirement age) and thus is a labor dispute within the original and exclusive jurisdiction of labor tribunals; the grievance machinery and voluntary arbitration under the CBA are the proper fora; the RTC lacks jurisdiction.

Supreme Court’s Jurisdictional Analysis and Holding

The Supreme Court reversed the CA and held that the RTC has jurisdiction. The Court reiterated the governing principle that jurisdiction is determined by the material allegations of the complaint and the character of the relief sought. Since petitioners’ primary relief was annulment of the CBA provision on constitutional and statutory grounds (including application of the Constitution and CEDAW), the dispute was not confined to labor law alone and was an ordinary civil action within the exclusive original jurisdiction of the RTC (Section 19[1], Batas Pambansa Blg. 129, as amended).

Application of Precedent and Legal Reasoning

The Court applied established jurisprudence distinguishing disputes that fall within labor tribunals’ competence (those resolvable by reference to the Labor Code, other labor statutes, or the CBA) from those that present rights arising from different legal sources and implicate general civil or constitutional law (citing Georg Grotjahn GMBH & Co. v. Isnani and related authorities). The Court stressed that questions of constitutionality or legality of contractual or CBA provisions engage judicial power and may not be effectively resolved by grievance machinery or voluntary arbitrators who lack authority to decide constitutional issues (citing Gonzales v. Climax Mining Ltd. and other precedents).

Grievance Machinery, Union Position, and Futility of Arbitration

The Court reasoned referral to the CBA’s grievance machinery and voluntary arbitration would be inappropriate and futile here because both union (FASAP) and management had earlier agreed to the contested provision and FASAP did not vigorously pursue meaningful renegotiation on behalf of affected female flight attendants. When a union and employer are united on a contested provision, the internal bilateral grievance mechanism cannot be expected to provide impartial relief to union members who dissent; thus, an impartial judicial forum is necessary (citing Pantranco North Express, Inc. v. NLRC).

Nature of the Determination Require

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