Case Summary (G.R. No. 88210)
Background of the Labor Dispute and Collective Bargaining Agreement
The dispute arose from the 1986-1989 Collective Bargaining Agreement (CBA) between PAL and PALEA, which included provisions for pay increases and the establishment of a joint PAL/PALEA Payscale Panel tasked with reviewing and updating pay scales and position classifications. The panel was formed and had completed initial evaluations by mid-1988. However, disagreements ensued regarding the minimum salary for the lowest job classification, with PALEA proposing a higher minimum than PAL, leading to a deadlock over wage adjustments. PALEA accused PAL of bargaining in bad faith.
Notice of Strike and Legal Issues Arising
PALEA filed a strike notice with the National Conciliation and Mediation Board (NCMB) on December 29, 1988, citing bargaining deadlock and bad faith bargaining by PAL. PAL opposed the strike, arguing it was premature as the existing CBA still had nine months before expiration, prohibiting termination or modification during its term pursuant to Article 253 of the Labor Code. The NCMB treated the strike notice as a preventive mediation case, which effectively suspended strike action. Despite this, PALEA conducted a strike vote and declared an actual strike on January 20, 1989, paralyzing PAL's operations.
Secretary of Labor’s Assumption of Jurisdiction and Order
PAL petitioned Secretary Drilon to assume jurisdiction over the dispute to prevent the strike, stressing the national interest given PAL’s status as the flag carrier and its critical economic role. The Secretary delayed action for seven days, during which the illegal strike commenced. He then assumed jurisdiction, ordered the strike to cease, mandated reinstatement of striking employees, and awarded monetary benefits to the union members while prohibiting PAL from taking disciplinary or retaliatory action against those involved in the strike. The Secretary also declared the strike valid on the basis that PALEA complied with procedural requirements notwithstanding the contradictory preventive mediation status.
Legal Issues Raised by Petitioner
PAL filed a petition for certiorari alleging grave abuse of discretion by the Secretary of Labor for:
- Declaring the strike valid despite being illegal.
- Prohibiting PAL from disciplining union officials and members responsible for the illegal strike.
- Failing to act promptly to avert the strike, which caused significant operational and economic damage.
Jurisdiction Over Legality of Strike
The Court emphasized that under Article 217(a)(5) of the Labor Code, the jurisdiction to determine the legality of strikes lies exclusively with Labor Arbiters, not the Secretary of Labor. The Secretary’s jurisdiction under Article 263 is limited to resolving the dispute’s issues and does not extend to ruling on strike legality. The legality of the PALEA strike was not submitted for the Secretary’s resolution. Thus, the Secretary acted without jurisdiction in declaring the strike valid.
Grounds for Illegality of the Strike
The Court held the PALEA strike illegal for three key reasons:
- Prematurity due to the existing 1986-1989 CBA which prohibited strikes until its expiration on September 30, 1989. Under Article 253 of the Labor Code, parties must maintain the status quo and cannot strike during the CBA’s term.
- Violation of the no-strike clause explicitly stated in the CBA prohibiting strikes during its duration.
- The NCMB’s classification of the strike notice as a preventive mediation case suspended strike action, making any strike during its pendency unlawful. PALEA failed to seek reconsideration of this declaration.
Rights of the Employer to Take Disciplinary Action
Given the strike’s illegality, PAL was entitled under Article 264 of the Labor Code to impose disciplinary measures, including termination, against union officers and members who participated in or committed illegal acts related to the strike. The Secretary of Labor exceeded his authority by restraining PAL from initiating such disciplinary actions, amounting to unlawful deprivation of property and denial of due p
Case Syllabus (G.R. No. 88210)
Background and Parties Involved
- The petitioner is Philippine Airlines, Inc. (PAL), the country's flag carrier engaged in national and domestic air transport.
- Respondents are the Secretary of Labor and Employment, Franklin M. Drilon, and the Philippine Airlines Employees Association (PALEA), the labor union representing various categories of PAL employees.
- The legal issue focuses on the Secretary of Labor’s authority to order PAL to reinstate union officers and members who participated in a strike characterized as illegal and to prohibit PAL from taking disciplinary or retaliatory actions against them.
The 1986-1989 Collective Bargaining Agreement (CBA) and Payscale Panel
- The CBA included provisions for pay increases for various employees under Section 1, Article V entitled "PAY SCALE."
- The agreement mandated the creation of a PAL/PALEA Payscale Panel tasked with conducting a comprehensive study, review, re-classification, and updating of job positions and payscales, targeting to complete it by January 1, 1988.
- By July 1988, the Job Evaluation Committee completed initial evaluation and reconciliation of positions.
- In November 1988, PALEA panel members proposed a minimum salary of PHP 3,349 for the lowest job classification (Job Grade 1), while PAL proposed PHP 2,310 plus PHP 200 across-the-board for those not covered by payscale adjustments.
- Negotiations deadlocked as PALEA demanded their proposed minimum salary, while PAL representatives claimed no authority to approve more.
- PALEA accused PAL of bargaining in bad faith for their refusal to meet the proposed pay levels.
Notice of Strike and Legal Disputes Leading to the Strike
- On December 29, 1988, PALEA filed a notice of strike citing bargaining deadlock and unfair labor practices, specifically PAL’s alleged bad faith bargaining.
- PAL moved to dismiss this notice on the grounds of prematurity, arguing that the existing CBA was still effective until September 30, 1989, and thus the issues raised were not strikeable.
- The core issues identified during conciliation included: (1) determination of minimum entry salary rate; (2) wage adjustments from payscale studies; and (3) retroactive pay or goodwill bonuses resulting from the revised payscales.
Mediation, Assumption of Jurisdiction, and the Strike
- Assistant conciliator advised PALEA that their strike issues were only appropriate for preventive mediation and thus not valid grounds for a lawful strike.
- Despite this, a National Conciliation and Mediation Board (NCMB) representative supervised a strike vote, contrary to prior orders preventing certification of such a vote.
- On January 13, 1989, PAL petitioned the Secretary of Labor to assume jurisdiction over the labor dispute to prevent the strike, citing PAL’s significant government equity, it