Case Digest: Halagueña, et al. vs PAL GR No. 172013

Halagueña, et al. vs PAL 

GR No. 172013                                                                 October 2, 2009

Facts:

Petitioners were employed as flight attendants of respondent on different dates prior to November 1996. They are members of FASAP union exclusive bargaining organization of the flightattendants, flight stewards and pursers. On July 2001, respondent and FASAP entered into a CBA incorporating the terms and conditions of their agreement for the years 2000 to 2005 (compulsory retirement of 55 for female and 60 for males).

In July 2003, petitioner and several female cabin crews, in a letter, manifested that the provision in CBA on compulsory retirement is discriminatory. On July 2004, petitioners filed a Special Civil Action for Declaratory Relief with issuanceof TRO with the RTC Makati. The RTC issued a TRO. After the denial of the respondent on itsmotion for reconsideration for the TRO, it filed a Petition with the CA. CA granted respondent’s petition and ordered lower court to dismiss the case. Hence, this petition.

Issue:

Whether or not the regular courts has jurisdiction over the case.

Ruling:

Yes. The subject of litigation is incapable of pecuniary estimation, exclusively cognizable by the RTC. Being an ordinary civil action, the same is beyond the jurisdiction of labor tribunals.

Not every controversy or money claim by an employee against the employer or vice-versa is within the exclusive jurisdiction of the labor arbiter. Actions between employees and employer where the employer-employee relationship is merely incidental and the cause of action precedes from a different source of obligation is within the exclusive jurisdiction of the regular court. 

Being an ordinary civil action, the same is beyond the jurisdiction of labor tribunals.The said issue cannot be resolved solely by applying the Labor Code. Rather, it requires the application of the Constitution, labor statutes, law on contracts and the Convention on the Elimination of All Forms of Discrimination Against Women, and the power to apply and interpret the constitution and CEDAW is within the jurisdiction of trial courts, a court of general jurisdiction. In GeorgGrotjahn GMBH & Co. v. Isnani, this Court held that not every dispute between an employer and employee involves matters that only labor arbiters and the NLRC can resolve in the exercise of their adjudicatory or quasi-judicial powers. The jurisdiction of labor arbiters and the NLRC under Article 217 of the Labor Code is limited to dispute arising from an employer-employee relationship which can only be resolved by reference to the Labor Code other labor statutes, or their collective bargaining agreement.