HALAGUENA vs. PHILIPPINE AIRLINES INC. FACTS:
Patricia Patrici a Hal Halagu agueña, eña, et. al, (Ha (Halagu lagueña) eña) are flig flight ht atte attenda ndants nts empl employe oyed d by Phil Philipp ippine ine Ai Airlin rlines es Inc. (PAL) as well as members of light Attendants and !tewards Association of the Philippines (A!AP), the e"clusi#e bargaining agent of flight attendants, flight stewards and pursers of PAL. Halagueña assails !ec. $%% of the &'A entered into by PALA!AP and A!AP, which pro#ides for a younger retirement age for female cabin attendants than those of their male counterparts, to be unconstitutional. ue to Halagueña*s claim, +obert . Anduia, President of A!AP submitted their -%-/ &'A proposa pro posals ls and man manifes ifested ted thei theirr wil willing lingnes ness s to comm commenc ence e the col collect lecti#e i#e barg bargain aining ing neg negotia otiation tions s between the management and the association, at the soonest possible time. Halagueña also filed before the +0& of 1a2ati, 'ranch $%3 a !pecial &i#il Action for eclaratory +elief with Prayer for the Issuance of 0emporary +estraining 4rder and 5rit of Preliminary In6unction against PAL PAL for the in#alidity of the assailed pro#ision of the &'A. 0he +0& e#entually e#entually granted such petition. Aggrie#ed, Aggrie# ed, PAL, PAL, filed a Petition for &ertiorari and Prohibition Prohibition with Prayer for a 0emporary 0emporary +estraining +estraining 4rder and 5rit of Preliminary In6unction with the &ourt of Appeals praying that the order of the +0&, which denied its ob6ection to its 6urisdiction, be annulled and set aside for ha#ing been issued without and7or with gra#e abuse of discretion amounting to lac2 of 6urisdiction. 0he &A granted PAL*s petition on the ground that the +0& has no 6urisdiction o#er a labor dispute, hence the case at bar. ISSUES:
5hether or not the +0 5hether +0& & has 6urisdictio 6urisdiction n o#e o#err the pet petitio itioners ners** acti action on cha challen llengin ging g the legality legality or constitutionality of the pro#isions on the compulsory retirement age contained in the &'A between respondent PAL and A!AP. HELD:
8es. 0he sub6ect of litigation is incapable of pecuniary estimation, e"clusi#ely cogniable by the +0&. 'eing an ordinary ci#il action, the same is beyond the 6urisdiction of labor tribunals. 9ot e#ery contro#ersy or money claim by an employee against the employer or #ice#ersa is within the e"clusi#e 6urisdiction of the labor arbiter. Actions between employees and employer where the employeremployee relationship is merely incidental and the cause of action precedes from a different source of obligation is within the e"clusi#e 6urisdiction of the regular court. Here, the employer employee relationship between the parties is merely incidental and the cause of action ultimately arose from different sources of obligation, i.e., the &onstitution and &:A5.
Case Digest: Halagueña, et al. vs PAL GR No. 1721! Halagueña, et al. vs PAL GR No. 1721! "#to$e% 2, 2& acts; Petitioners were employed as flight attendants of respondent on different dates prior to 9o#ember $<<=. 0hey are members of A!AP union e"clusi#e bargaining organiation of the flightattendants, flight stewards and pursers. 4n >uly -$, respondent and A!AP entered into a &'A incorporating the terms and conditions of their agreement for the years - to -/ (compulsory retirement of // for female and = for males). In >uly -?, petitioner and se#eral female cabin crews, in a letter, manifested that the pro#ision in &'A on compulsory retirement is discriminatory. 4n >uly -%, petitioners filed a !pecial &i#il Action for eclaratory +elief with issuanceof 0+4 with the +0& 1a2ati. 0he +0& issued a 0+4. After the denial of the respondent on itsmotion for reconsideration for the 0+4, it filed a Petition with the &A. &A granted respondent*s petition and ordered lower court to dismiss the case. Hence, this petition. Issue; 5hether or not the regular courts has 6urisdiction o#er the case. +uling; 8es. 0he sub6ect of litigation is incapable of pecuniary estimation, e"clusi#ely cogniable by the +0&. 'eing an ordinary ci#il action, the same is beyond the 6urisdiction of labor tribunals. 9ot e#ery contro#ersy or money claim by an employee against the employer or #ice#ersa is within the e"clusi#e 6urisdiction of the labor arbiter. Actions between employees and employer where the employeremployee relationship is merely incidental and the cause of action precedes from a different source of obligation is within the e"clusi#e 6urisdiction of the regular court. 'eing an ordinary ci#il action, the same is beyond the 6urisdiction of labor tribunals.0he said issue cannot be resol#ed solely by applying the Labor &ode. +ather, it re@uires the application of the &onstitution, labor statutes, law on contracts and the &on#ention on the :limination of All orms of iscrimination Against 5omen, and the power to apply and interpret the constitution and &:A5 is within the 6urisdiction of trial courts, a court of general 6urisdiction. In eorgrot6ahn 1'H B &o. #. Isnani, this &ourt held that not e#ery dispute between an employer and employee in#ol#es matters that only labor arbiters and the 9L+& can resol#e in the e"ercise of their ad6udicatory or @uasi6udicial powers. 0he 6urisdiction of labor arbiters and the 9L+& under Article -$3 of the Labor &ode is limited to dispute arising from an employeremployee relationship which can only be resol#ed by reference to the Labor &ode other labor statutes, or their collecti#e bargaining agreement.
HALAGUE'A v. PAL
.+. 9o. $3-$?C 4ctober -, -< Ponente; >. Peralta
(AC)S: Petitioners were employed as female flight attendants of respondent Philippine Airlines (PAL) on different dates prior to 9o#ember --, $<<=. 0hey are members of the light Attendants and !tewards Association of the Philippines (A!AP), a labor organiation certified as the sole and e"clusi#e certified as the sole and e"clusi#e bargaining representati#e of the flight attendants, flight stewards and pursers of respondent. 4n >uly $$, -$, respondent and A!AP entered into a &ollecti#e 'argaining Agreement incorporating the terms and conditions of their agreement for the years - to -/, hereinafter referred to as PALA!AP &'A. !ection $%%, Part A of the PALA!AP &'A, pro#ides that; A. or the &abin Attendants hired before -- 9o#ember """" ?.
$<<=;
&ompulsory +etirement
!ub6ect to the grooming standards pro#isions of this Agreement, compulsory retirement shall be fiftyfi#e (//) for females and si"ty (=) for males. " " ". In a letter dated >uly --, -?, petitioners and se#eral female cabin crews manifested that the aforementioned &'A pro#ision on compulsory retirement is discriminatory, and demanded for an e@ual treatment with their male counterparts. 0his demand was reiterated in a letter by petitionersD counsel addressed to respondent demanding the remo#al of gender discrimination pro#isions in the coming renegotiations of the PALA!AP &'A. 4n >uly -<, -%, petitioners filed a !pecial &i#il Action for eclaratory +elief with Prayer for the Issuance of 0emporary +estraining 4rder and 5rit of Preliminary In6unction with the +egional 0rial &ourt (+0&) of 1a2ati &ity, 'ranch $%3
ISSUE: 5hether the +0& has 6urisdiction o#er the petitionersD action challenging the legality or constitutionality of the pro#isions on the compulsory retirement age contained in the &'A between respondent PAL and A!AP.
HELD: >urisdiction of the court is determined on the basis of the material allegations of the complaint and the character of the relief prayed for irrespecti#e of whether plaintiff is entitled to such relief. 0he said issue cannot be resol#ed solely by applying the Labor &ode. +ather, it re@uires the application of the &onstitution, labor statutes, law on contracts and the &on#ention on the :limination of All orms of iscrimination Against 5omen, and the power to apply and interpret the constitution and &:A5 is within the 6urisdiction of trial courts, a court of general 6urisdiction.
In eorg rot6ahn 1'H B &o. #. Isnani, this &ourt held that not e#ery dispute between an employer and employee in#ol#es matters that only labor arbiters and the 9L+& can resol#e in the e"ercise of their ad6udicatory or @uasi6udicial powers. 0he 6urisdiction of labor arbiters and the 9L+& under Article -$3 of the Labor &ode is limited to disputes arising from an employeremployee relationship which can only be resol#ed by reference to the Labor &ode, other labor statutes, or their collecti#e bargaining agreement. 5here the principal relief sought is to be resol#ed not by reference to the Labor &ode or other labor relations statute or a collecti#e bargaining agreement but by the general ci#il law, the 6urisdiction o#er the dispute belongs to the regular courts of 6ustice and not to the labor arbiter and the 9L+&. In such situations, resolution of the dispute re@uires e"pertise, not in labor management relations or in wage structures and other terms and conditions of employment, but rather in the application of the general ci#il law. &learly, such claims fall outside the area of competence or e"pertise ordinarily ascribed to labor arbiters and the 9L+& and the rationale for granting 6urisdiction o#er such claims to these agencies disappears
