G.R. No. 200088 , February 26, 2018
PHILIPPINE AIRLINES, INC., Petitioner, vs. AIRLINE PILOTS ASSOCIATION OF THE PHILIPPINES, ET AL., Respondents.

FACTS

The case originated from a labor dispute between Philippine Airlines, Inc. (PAL) and the Airline Pilots Association of the Philippines (ALPAP). On June 5, 1998, ALPAP staged a strike despite a prior order from the Secretary of Labor and Employment (SOLE) assuming jurisdiction over the dispute and prohibiting such action. The SOLE subsequently declared the strike illegal and ordered the loss of employment status for participating officers, a ruling ultimately affirmed with finality by the Supreme Court. On April 22, 2003, PAL filed a complaint for damages before the Labor Arbiter (LA), alleging that the illegal strike, particularly the abandonment of aircraft by pilots, caused it to incur over ₱731 million in actual damages from passenger accommodations, operational expenses, and lost income.
The Labor Arbiter dismissed the complaint, citing lack of jurisdiction and prescription. The NLRC affirmed the dismissal for lack of jurisdiction but deleted the finding on prescription. The Court of Appeals partially granted PAL’s petition, agreeing that labor tribunals lacked jurisdiction but ruling that the NLRC gravely abused its discretion in affirming the LA’s finding on prescription. PAL elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Labor Arbiter and the NLRC have jurisdiction over PAL’s claim for damages arising from the illegal strike.

RULING

No. The Supreme Court denied the petition and affirmed the dismissal of PAL’s complaint for lack of jurisdiction. The Court held that PAL’s claim for damages is not within the original and exclusive jurisdiction of labor tribunals. While Article 217(a)(4) of the Labor Code grants the LA jurisdiction over claims for damages arising from employer-employee relations, this provision pertains to claims by workers. Claims for damages by the employer, such as PAL’s, are governed by Article 217(c), which refers to “all other claims arising from employer-employee relations,” but this is not an exclusive grant.
The nature of PAL’s action is a claim for actual, exemplary, and moral damages based on alleged tortious acts—the deliberate abandonment of aircraft and the illegal strike. These are civil disputes predicated on quasi-delict, not a simple breach of the Collective Bargaining Agreement. Jurisdiction over such claims properly lies with the regular courts. The Court clarified that the SOLE’s assumption of jurisdiction under Article 263(g) of the Labor Code over the labor dispute does not automatically extend to a claim for damages by the employer, which remains a separate civil action. The ruling of the Court of Appeals was thus affirmed, reinstating the Labor Arbiter’s dismissal of the complaint solely on the ground of lack of jurisdiction.