Case Summary (G.R. No. 10073)
Key Dates
• April 3, 1993 – Alleged currency smuggling incident in Hong Kong.
• February 22, 1995 – PAL’s memoranda of dismissal issued to private respondents.
• April 3, 1995 – NLRC grants temporary mandatory injunction enjoining enforcement of dismissals.
• May 31, 1995 – NLRC denies PAL’s motion for reconsideration.
• March 20, 1998 – Supreme Court decision.
Applicable Law
• 1987 Philippine Constitution (security of tenure).
• Labor Code of the Philippines, Articles 217(a) (original and exclusive jurisdiction of labor arbiter for illegal dismissal cases) and 218(e) (injunctive powers of the NLRC).
• Section 1, Rule XI of the NLRC Rules (ancillary injunctive power).
Facts
Pineda and Cabling, serving as flight stewards on PAL Flight PR300/03, were implicated in the interception of a bag containing approximately ₱2.5 million at Hong Kong’s Kai Tak Airport. After initial investigations, PAL’s Disciplinary Board held two hearings: at the first, identification procedures were flawed; at the second, the principal alleged co-conspirator, Joseph Abaca, exculpated them and suggested alternate culprits. Despite this, PAL issued dismissal memoranda in February 1995, effective immediately.
Procedural Posture before the NLRC
Instead of filing a complaint for illegal dismissal with the Labor Arbiter, the private respondents directly petitioned the NLRC for a temporary and preliminary injunction to:
- Restrain enforcement of the dismissal memoranda.
- Order their reinstatement pending final resolution.
- Eventually make the injunction permanent and award backwages, moral and exemplary damages, and attorney’s fees.
The NLRC granted a temporary mandatory injunction on April 3, 1995, and, upon PAL’s motion for reconsideration, denied relief on May 31, 1995.
Issue
Whether the NLRC, in the absence of an illegal dismissal complaint filed with the Labor Arbiter, may entertain a direct petition for injunction and order PAL to reinstate its employees.
Analysis
Nature of Injunctive Relief
• Injunction is a provisional, equitable remedy intended to prevent irreparable injury when no adequate legal remedy exists.
• Under Article 218(e), the NLRC may enjoin prohibited acts or require performance “in any labor dispute” that could cause grave or irreparable damage.
• Rule XI, Section 1 of the NLRC Rules limits injunctions to disputes already pending before the Commission or Labor Arbiters.Jurisdictional Scope
• Article 217(a) vests the Labor Arbiter with original and exclusive jurisdiction over illegal dismissal cases and related claims (reinstatement, backwages, damages).
• The NLRC’s jurisdiction in such cases is strictly appellate; it may not entertain an independent action for injunction that seeks relief reserved for the Labor Arbiter.Adequacy of Legal Remedy
• PAL contended that an illegal dismissal suit is an “inadequate” remedy because of its purported three-year duration.
• The Supreme Court held that an “adequate” remedy is one that is appropriate, sufficient, and capable of promptly redressing the injury.
• The remedy of filing with the Labor Arbiter is both expressly provided by law and presumed adequate.Irreparable Injury
• To justify injunction, injury must be irreparable or not susceptible to fair monetary compensation.
• Reinstatement and backwages under Article 279 of the Labor Code constitute appropriate relief for wrongful dismissal, negating the claim of irreparable injury.Precedential Misreading
• The NLRC relied on a supposed Supreme Court endorsement of its mandatory injunctive power in Chemo-Technisch
Case Syllabus (G.R. No. 10073)
Facts of the Case
- Private respondents Ferdinand Pineda and Godofredo Cabling served as flight stewards of Philippine Airlines, Inc. (PAL).
- On April 3, 1993, Joseph Abaca, an Avionics Mechanic in Hong Kong, was intercepted at Kai Tak International Airport carrying some ₱2.5 million in Philippine currency hidden in a bag.
- PAL’s Security and Fraud Prevention Sub-Department summoned Pineda and Cabling for investigation of alleged co-conspiracy in the smuggling incident.
- Formal disciplinary hearings were delayed until January 20, 1995; identification procedure was anomalous, and initial line-up was empty.
- At a January 25, 1995 hearing, Abaca exculpated Pineda and Cabling, volunteered that he was the courier, and identified another mechanic as the money’s owner.
- Without further summons, PAL issued Memoranda dated February 22 and February 3, 1995, terminating Pineda’s and Cabling’s services for alleged violation of PAL’s Code of Discipline, effective immediately.
Procedural History
- Private respondents did not file a complaint for illegal dismissal with the labor arbiter.
- On April 3, 1995, they directly filed with the NLRC a petition for injunction praying for:
• A temporary restraining order and preliminary mandatory injunction to enjoin enforcement of the February 22, 1995 dismissal.
• Permanent injunction, reinstatement to former positions pending case resolution, full backwages, moral and exemplary damages of ₱500,000 each, attorney’s fees, and costs. - On April 3, 1995, the NLRC (First Division) issued a temporary mandatory injunction ordering PAL to cease enforcing the dismissals and reinstate respondents.
- PAL moved for reconsideration on May 4, 1995; the NLRC denied it on May 31, 1995.
Petition for Injunction before the NLRC
- Private respondents invoked Article 218(e) of the Labor Code, claiming:
• PAL’s Code of Discipline was illegal per PAL vs. NLRC (G.R. No. 85985, Aug. 13, 1993) for lack of employee participation under R.A. 6715.
• The dismissal memoranda were whimsical, baseless, and premature causing grave and irreparable injury.
• The NLRC had power to issue prohibitory and mandatory injunctions in labor disputes.
• A writ of injunction was their only speedy and adequate legal remedy.
NLRC’s Issuance of Temporary Mandatory Injunction
- The NLRC granted the petition on April 3, 1995, considering that:
• Respondents faced arbitrary dismissals under an illegal Code of Discipline.
• Absence of employee participation rendered the Code void ab initio.
• Article 218(e) con