G.R. No. 172013; October 2, 2009
PATRICIA HALAGUEÑA, ET AL., Petitioners, vs. PHILIPPINE AIRLINES INCORPORATED, Respondent.

FACTS

Petitioners are female flight attendants employed by Philippine Airlines (PAL) and are members of the Flight Attendants and Stewards Association of the Philippines (FASAP). The PAL-FASAP Collective Bargaining Agreement (CBA) for 2000-2005 contained Section 144, Part A, which set the compulsory retirement age at fifty-five (55) for females and sixty (60) for males. Petitioners, claiming this provision was discriminatory, demanded equal treatment. After their demands were not met, they filed a Special Civil Action for Declaratory Relief with the Regional Trial Court (RTC) of Makati, seeking a declaration of the provision’s nullity for violating the Constitution, the Labor Code, and the Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW). The RTC assumed jurisdiction, issued a temporary restraining order, and later a writ of preliminary injunction against the provision’s implementation.
PAL challenged the RTC’s jurisdiction via a Petition for Certiorari before the Court of Appeals (CA). The CA granted PAL’s petition, annulled the RTC’s orders, and directed the dismissal of the case. The CA ruled that the dispute involved the interpretation and implementation of a CBA provision—a matter arising from employer-employee relations—and thus fell under the exclusive jurisdiction of voluntary arbitrators or the National Labor Relations Commission (NLRC), not the regular courts.

ISSUE

Whether the Regional Trial Court has jurisdiction over an action seeking a declaratory judgment on the constitutionality and legality of a provision in a Collective Bargaining Agreement.

RULING

The Supreme Court REVERSED the Court of Appeals and REINSTATED the RTC’s assumption of jurisdiction. The Court held that the RTC properly exercised jurisdiction over the petition for declaratory relief. The core of the petition was a direct challenge to the constitutionality and legality of the CBA provision based on alleged violations of constitutional mandates on equal protection, statutes like the Labor Code, and an international treaty (CEDAW). This raised a pure question of law.
The Court distinguished this from a labor dispute over the interpretation or implementation of the CBA, which would indeed fall under the jurisdiction of labor arbiters or voluntary arbitrators. Here, petitioners were not asking for a construction of the provision’s terms or seeking a remedy for its application to a specific grievance. Instead, they sought a judicial declaration that the provision itself was void from the beginning for being contrary to law and public policy. Such an action, where the subject is incapable of pecuniary estimation and involves the validity of a contract based on constitutional grounds, is within the general jurisdiction of the RTC. The labor tribunals’ expertise lies in resolving disputes arising from employer-employee relations, not in adjudicating fundamental constitutional issues. Therefore, the RTC was competent to hear and decide the case.