PATRICIA HALAGUEA, MA. ANGELITA L. PULIDO, MA. TERESITA P.
SANTIAGO, MARIANNE V. KATINDIG, BERNADETTE A. CABALQUINTO,
LORNA B. TUGAS, MARY CHRISTINE A. VILLARETE, CYNTHIA A. STEHMEIER, ROSE ANNA G. VICTA, NOEMI R. CRESENCIO, AND OTHER FLIGHT ATTENDANTS OF PHILIPPINE AIRLINES, PETITIONERS, VS. PHILIPPINE AIRLINES INCORPORATED, RESPONDENT. G.R. No. 172013, October 02, 2009 PERALTA, J: TOPIC: Jurisidiction of the Labor Tribunals; Question of constitutionality of a provision of a CBA. FACTS: Herein petitioners are employed as female attendants of respondent Philippine Airlines Incorporated (PAL), they were also members of Flight Attendants and Stewards Association of the The Philippines (FASAP), the sole and exclusive bargaining representative of the flight attendants. On July 2011, FASAP entered into a CBA with the PAL, Section 144 thereof provides that the compulsory retirement age of a female attendant shall be 55, while 60 for the males. Petitioners filed a Special Civil Action for Declaratory Relief with RTC of Makati, alleging the unconstitutionality of the provision for being discriminatory. The RTC in upholding its jurisdiction ruled that Section 144 is unconstitutional as it was discriminatory, the allegations in the petition do not make out a labor dispute arising out of employer-employee relationship, nor does not involve a claim against the respondent. On Appeal with the Court of Appeals, it reversed the decision of the RTC, ruling that the RTC has no jurisdiction to hear the case as it has no jurisdiction over the subject matter, following the prayer of the respondents that it is the labor courts that has jurisdiction over the issue. Hence, the aggrieved petitioners filed a Petition for Review on Certiorari with the SC, alleging that the CA erred in ruling that the subject matter is a labor dispute. ISSUE: Whether the question of constitutionality of Section 144 of the CBA falls within the jurisdiction of the labor courts. HELD: NO, as jurisdiction is determined on the basis of the material allegations of the complaint and the character of the relief prayed for, it
was clearly spelled out in the complaint of herein petitioners, as they
prayed that Section 144 of the CBA to be declared unconstitutional. As the subject is incapable of pecuniary estimation and an ordinary, the RTC has jurisdiction to hear the case, and beyond the jurisdiction of the labor tribunals. As the said issue cannot be resolved by applying the Labor Code, but rather by application of the Constitution, Labor statues, Law on Contracts and the Convention n the Elimination of All Forms of Discrimination against women, such power to apply and interpret said sources of law is within the jurisdiction of the RTC, a court of general jurisdiction. DOCTRINE: Not every case arising out of employer-emplyee relationship falls within the jurisdiction of the Labor Courts, actions in which such relationship is merely incidental and the cause of action precedes from a different source, it would divest jurisdiction from the Labor Courts.