Title
Philippine Airlines, Inc. vs. Airline Pilots Association of the Philippines
Case
G.R. No. 200088
Decision Date
Feb 26, 2018
Philippine Airlines sued ALPAP for damages after an illegal strike, but labor tribunals ruled jurisdiction over claims, deeming them resolved with the strike's final illegality ruling.

Case Summary (G.R. No. 200088)

Applicable Law

The applicable legal framework revolves around the 1987 Philippine Constitution and the Labor Code, specifically Article 263(g) regarding the jurisdiction of the Secretary of Labor over labor disputes and Article 217 concerning the jurisdiction of Labor Arbiters and the NLRC over actions for damages arising from employer-employee relations.

Legal Proceedings and Rulings

The Labor Arbiter dismissed PAL's complaint for damages, claiming lack of jurisdiction, as the SOLE had not certified the controversy for arbitration and the matter was outside the agreed framework for dispute resolution. The LA also noted that PAL's complaint was time-barred under the prescriptive period detailed in Article 291 of the Labor Code. The NLRC affirmed this, further stating that claims based on tortious acts required resolution in regular courts rather than labor tribunals, due to the absence of a reasonable connection to the employer-employee relationship.

Court of Appeals Decision

The CA partially granted PAL's petition, agreeing that the NLRC correctly found a lack of jurisdiction at the labor tribunal level but reversed the conclusion on the prescription of PAL's claim. The CA contended that the exclusive jurisdiction over the claim for damages lay with regular courts for claims not grounded solely in labor law. It found that PAL's cause of action for damages accrued only after the Supreme Court's final resolution on the legality of the strike.

Supreme Court's Ruling

The Supreme Court ruled that the NLRC and the LA did indeed have jurisdiction over PAL's claims for damages because they arose from a labor dispute connected to unfair labor practices. The Court emphasized that the claim for damages was intricately linked to the illegal strike and, therefore, inherently a labor controversy. The "reasonable connection rule" was examined, illustrating that if damages stem from actions closely tied to labor relations, they should be resolved within the labor arbitration framework.

Jurisdiction and Finality

Despite recognizing the jurisdiction of labor tribunals over actions for damages related to strikes, the Court ultimately concluded that PAL's claim was barred under the doctrine of immutability of final judgment. Given that the SOLE had already adju

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