Philippine Airlines v. Airline Pilots Association Of The Philippines
Philippine Airlines, Inc. v. Airline Pilots Association of the Philippines, et al., G.R. No. 200088, February 26, 2018
- Procedural (Remedial Law)
- jurisdiction
- illegal strike
- damages
- labor arbiter
- NLRC
- reasonable causal connection
- split jurisdiction
- immutability of judgment
- waiver
- assumption of jurisdiction
- SOLE
- Article 217 Labor Code
I. Facts of the Case
Philippine Airlines, Inc. (PAL) sued the Airline Pilots Association of the Philippines (ALPAP), its officers and members for damages arising from an illegal strike in June 1998, during which striking pilots abandoned PAL aircraft. The strike had earlier been declared illegal by the SOLE in a resolution that became final. The dispute concerns whether the Labor Arbiter and NLRC, or the regular courts, have jurisdiction over PAL's later damages claim.
December 9, 1997
ALPAP, the registered exclusive bargaining agent of PAL's commercial pilots, filed a notice of strike with DOLE alleging that PAL committed unfair labor practice.
December 23, 1997
The Secretary of Labor and Employment (SOLE) assumed jurisdiction over the dispute and prohibited ALPAP from striking or committing any act that could exacerbate the dispute.
June 5, 1998
Despite the SOLE's prohibition, ALPAP staged a strike.
June 6, 1998
On the second day of the strike, the striking pilots abandoned three PAL aircraft (PR 730 and PR 741 at Bangkok, and PR 104 at San Francisco), stranding passengers. PAL allegedly incurred expenses for hotels, meals, parking and operations, and suffered ticket refunds and lost income.
June 7, 1998
The SOLE issued a return-to-work order, which ALPAP defied by continuing the strike.
June 1, 1999
The SOLE resolved that the strike was illegal and that the officers who participated lost their employment status. The CA upheld this in CA-G.R. SP No. 54880.
April 10, 2002
In G.R. No. 152306 the Supreme Court dismissed ALPAP's petition for failure to show grave abuse of discretion or reversible error. The resolution became final on August 29, 2002.
April 22, 2003
Almost eight months after finality, PAL filed a complaint for damages before the Labor Arbiter against ALPAP and some of its officers and members. It claimed ₱731,078,988.59 actual damages, ₱300,000,000 exemplary damages and ₱3,000,000 attorney's fees.
April 22, 2008
The Labor Arbiter dismissed the complaint for lack of jurisdiction. It held that jurisdiction over all issues arising from the dispute, including damages, remained with the SOLE because there was no certification to the NLRC or voluntary arbitration. It also held the action prescribed under Article 291 of the Labor Code, counted from June 5 or 7, 1998.
April 27, 2009
The NLRC affirmed the Labor Arbiter with modification, deleting 'for lack of merit'. It ruled that labor tribunals have no jurisdiction because the claims rest on tortious acts and breach of contractual obligation, which are civil disputes for regular courts. Reconsideration was denied on February 26, 2010.
August 26, 2011
On PAL's Rule 65 petition, the CA (CA-G.R. SP No. 113985) partially granted relief. It held that regular courts, not the SOLE or Labor Arbiter, have jurisdiction over the damages claim, and that the action had not prescribed because it accrued on August 29, 2002. Reconsideration was denied on January 5, 2012.
PAL filed a Rule 45 petition before the Supreme Court. It maintained that its damages claim should be heard by the labor tribunals.
II. Issues
Whether the NLRC and the Labor Arbiter have jurisdiction over PAL's claims against the respondents for damages incurred as a consequence of the latter's actions during the illegal strike.
III. Ruling
Whether the NLRC and the Labor Arbiter have jurisdiction over PAL's claims against the respondents for damages incurred as a consequence of the latter's actions during the illegal strike.
Labor tribunals, not regular courts, have jurisdiction over damages arising from the strike because the claim is reasonably connected to the employer-employee relationship. But because the SOLE had assumed jurisdiction over the whole dispute, the damages claim was deemed included in the SOLE's final resolution, so the Labor Arbiter had no jurisdiction to hear it anew and PAL's claim was waived.
How the Court reasoned
- Under Article 217 of the Labor Code, Labor Arbiters have original jurisdiction over claims for damages arising from employer-employee relations. Under the reasonable causal connection rule, a damages claim falls within labor jurisdiction if it has a reasonable connection to that relationship.
- The Court agreed with PAL that its claim for damages arising from the illegal strike, including the abandonment of aircraft by its pilots, has a reasonable connection with its employer-employee relationship with the respondents. The CA and NLRC therefore erred in treating it as a purely civil dispute for regular courts.
- Sending the claim to the trial court would violate the rule against split jurisdiction, which requires that a controversy and all its incidents be resolved in one forum rather than divided between courts and labor tribunals.
- Under Article 263(g), when the SOLE assumes jurisdiction over a labor dispute, the SOLE has authority over all questions and controversies arising from it. Once the SOLE assumed jurisdiction, PAL's damages claim was deemed included in the dispute, even though the SOLE's resolution and the final Supreme Court resolution did not mention damages.
- Since the SOLE's resolution was affirmed by the CA and by the Supreme Court and became final on August 29, 2002, the Labor Arbiter was divested of jurisdiction over the damages claim. Relitigating it is barred by the doctrine of immutability of final judgment.
- PAL failed to raise the damages claim while the illegal strike case was pending before the SOLE. Its claim is therefore deemed waived, and the Labor Arbiter's dismissal for lack of jurisdiction is reinstated.
“Consequently, when the SOLE assumed jurisdiction over the labor dispute, the claim for damages was deemed included therein.”
Rule applied
Article 217 [now Article 224] of the Labor Code, as amended by R.A. No. 6715; Article 263(g) of the Labor Code (assumption of jurisdiction by the SOLE); reasonable causal connection rule; rule against split jurisdiction; doctrine of immutability of final judgment
Doctrines
Under the reasonable causal connection rule, actions for damages arising from a labor strike that are reasonably connected to the employer-employee relationship fall within the jurisdiction of labor tribunals, not regular courts.
Splitting jurisdiction is not allowed: a regular court may not hear a damages claim arising from a labor dispute over which the SOLE has assumed jurisdiction.
When the SOLE assumes jurisdiction over a labor dispute, all questions and controversies arising from it, including claims for damages, are deemed included in that assumption of jurisdiction.
A claim for damages not raised during the pendency of the strike case before the SOLE is deemed waived. Once the SOLE's resolution is final, relitigating the claim is barred by the doctrine of immutability of final judgment.
Final Disposition
WHEREFORE, the petition is DENIED in effect: the 26 August 2011 Decision and 5 January 2012 Resolution of the Court of Appeals in CA-G.R. SP No. 113985 are SET ASIDE, and the 22 April 2008 Decision of the Labor Arbiter dismissing PAL's complaint for lack of jurisdiction is REINSTATED.
Notes
Penned by Justice Martires (Third Division). The Court agreed with PAL that the claim is within labor jurisdiction, but still reinstated the Labor Arbiter's dismissal because the claim was deemed included in the final SOLE resolution and waived.