Case Summary (G.R. No. 55159)
Facts of the Case
Armando Dolina was enrolled in the Philippine Airlines aviation school for pilot training beginning January 16, 1973. The training agreement assured him regular employment upon completion of the course, which he completed on January 25, 1974. After fulfilling additional qualification courses, his employment timeline included various extensions due to a lack of sufficient flying hours, culminating in a situation where, after multiple assessments, he was deemed not qualified for regular employment due to unacceptable psychological test results. Following a recommendation for termination, Dolina filed a complaint for illegal dismissal and was subsequently placed under preventive suspension. His reinstatement was ordered, and a resolution was sought through arbitration.
Procedural Posture
The Labor Arbiter ultimately ruled in favor of PAL's application for clearance to terminate Dolina, which meant his dismissal was deemed valid. Dolina appealed this decision to the NLRC, which affirmed the Labor Arbiter's ruling but also mandated that Dolina be restored to the payroll with back wages effective April 1, 1979, citing an agreement between the parties that mandated his inclusion on the payroll until the case was definitively resolved.
Issue Raised
The central issue examined by the Supreme Court was whether the NLRC had committed grave abuse of discretion by ordering the continued payment of Dolina’s salaries despite affirming the Labor Arbiter's dismissal ruling. PAL contested this decision, asserting that the NLRC should not have ordered compensation since Dolina was validly dismissed.
Contractual Interpretation
The Supreme Court discussed the interpretation of the agreement between Dolina and PAL regarding his payroll status pending the resolution of the case. The court identified that the intentions of the parties should be ascertained in light of the context of the agreement. The term “pending final resolution of the case by arbitration” was interpreted to encompass only proceedings before the Labor Arbiter, concluding that any appeals were separate from that arbitration process.
NLRC's Error Reviewed
The Supreme Court highlighted the inconsistency in NLRC's decision, which affirmed the validity of Dolina's dismissal yet mandated salary payments. It clarified that awarding salaries post-dismissal contradicts established legal principles of compensation tied to work actually rendered, reinforcing the doctrine that an employee cannot receive pay without performing
Case Syllabus (G.R. No. 55159)
Case Background
- This case involves a petition for certiorari filed by Philippine Airlines, Inc. (PAL) against the National Labor Relations Commission (NLRC) and Armando Dolina.
- The petition specifically contests the NLRC's decision, which ordered PAL to reinstate Dolina to its payroll and to pay his salaries retroactively from April 1, 1979, "until this case is finally resolved."
Facts of the Case
- Armando Dolina was admitted to the Philippine Airlines Aviation School for pilot training on January 16, 1973, with a commitment from PAL for regular employment upon course completion.
- Dolina completed his training on January 25, 1974, and subsequently undertook an equipment qualification course until October 4, 1974.
- He received his Commercial Pilot license on October 9, 1974, and was appointed as a Limited First Officer for a temporary six-month period.
- Dolina's appointments were extended multiple times due to insufficient flying hours, with his last extension being until April 30, 1976, when he finally completed the required 500 flying hours.
- On August 17, 1976, Dolina's "Adaptability Rating" was deemed "unacceptable," leading to a recommendation for his termination by the Pilot Acceptance Qualifications Board.
- Following a preventive suspension on October 1, 1976, Dolina filed a complaint for illegal dismissal on October 6, 1976.
- The Department of Labor lifted his suspension and ordered reinstatement with back wages, which was later rendered moot by an agreeme