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LABOR LAW

Halaguena et al. vs. PAL


GR 172013, October 2, 2009

FACTS:
Petitioners are flight attendants of PAL employed prior to 11/22//1996 and members of Flight Attendants
and Stewards Association of the PHL (FASAP), a duly registered labor organization for FA, flight
stewards and pursers. On July 11, 2001 FASAP entered into a CBA with PAL for the years 2000-2005
otherwise known as PAL-FASAP CBA. Sec. 144, Part A of which provides a compulsory retirement of 55
years for females and 60 years for males. On July 29. 2004 petitioner filed a Special Civil Action for
Declaratory Relief with Prayer for the Issuance of TRO and Writ of Preliminary Injunction with RTC Makati
City br. 147. RTC issued a TRO against the implementation of Sec. 144, Part A of PAL-FASAP CBA.

Respondent filed an omnibus motion seeking motion for reconsideration of the court's assumption of
jurisdiction over the matter, the same being denied.

CA ruled in favor of respondent reversing the lower court's decision to assume jurisdiction over the case.
Petitioner's motion for reconsideration over the matter was denied.

ISSUE:

1. Is the issue a labor dispute?

2. Does the lower court have jurisdiction over the complaint?

RULING:
1. The issue at hand is not a labor dispute since it involves the constitutionality of Sec. 144, Part
A of PAL-FASAP CBA for 2000-2005. In case at bar the employer-employee relationship is merely
incidental. The issue at hand is not limited to the application of PD 442 as amended.

2. Yes, the issue at hand is the constitutionality of Sec. 144, Part A of PAL-FASAP CBA, which
then falls under the jurisdiction of the court since it involves a question of fact. In addition, jurisdiction of
the court is determined on the basis of the material allegations of the complaint and the character of the
relief prayed for irrespective of whether the plaintiff is entitled to such relief.

Petition partly granted. CA decision is reversed and set-aside. RTC is directed to continue with the case
to determine through trial how Sec. 144, Part A of PAL-FASAP CBA is violative of the constitution.

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