i.

Student Name:
Michelle C. Llaneta-Villamora

ii. Complete Case Title Citation:

Philippine Airlines Inc. v. Alberto Santos Jr. et.al., (G.R. No. 77875, February 4,
1993.

iii. Statement of the Issue:

Whether or not the public respondent NLRC behaved with significant misuse of
authority due to lack of jurisdiction in setting aside the order of dismissal of the labor
arbitrator to private respondents.

iv. Complainant’s Arguments:

The Plaintiff contends that, because the grievance mechanism has been set up for
both the workers and the management as a tool to deal with any issues that may occur
in the course of their partnership, employees are obligated to bring the matter before
the management and to allow the management the opportunity to enforce any
corrective action that may be taken. Under normal circumstances, the employee does
not preclude the settlement of his / her grievance, however, he / she has the obligation
to maintain the status qou. In addition, the plaintiff claims that the respondent
workers have a duty, just as management has, to resolve all labor disputes by friendly
talks referred to in Article IV of Section 1 of the CBA. Section 2 of the CBA should
also not be strictly interpreted. Before the prescriptive duration of five days starts to
run, two concurrent conditions must be fulfilled, i.e. the submission of the petition
and the negotiation between the shop steward and the division manager. Section 2 is
not self-executing; the mere filing of the complaint does not cause the tolling of the
specified time.

v. Respondent’s Argument:
Abad's inability to act on the matter may have been due to inadvertent petitioners,
but it is simply too much of an injustice to make workers suffer the dire consequences
of it. While the latter were willing to resolve their grievance with their employer, the
latter closed the door to this possibility by not appointing anyone else to look into the
matter during Abad’s absence. As a result, private respondents could not be criticized
for thinking that the impact of the CBA on their behalf had already given rise to the
controversy.

vi. Instruction Learned:

In resolving labor disputes the court apply with due care the policies under the
labor laws and the pertinent provisions of the Collective Bargaining Agreement.
Collective bargaining is the process in which working people, through their unions,
negotiate contracts with their employers to determine their terms of employment,
including pay, benefits, hours, leave, job health and safety policies, ways to balance
work and family, and more. Collective bargaining is a way to solve workplace
 problems. (https://aflcio.org/what-unions-do/empower-workers/collective-
bargaining).
Thus, employers cannot necessarily reject or change their obligations in order to
benefit them.

Decision of the Court:

The instant petition was denied and the assailed decision of respondent National
Labor Relations Commission is affirmed. Judgment is immediately executory.

vii. Ratio:
It is a fact that the sympathy of the court is on the side of the working classes, not
just because the Constitution imposes such solidarity, but also because of the one-
sided relationship between labor and capital. The constitutional provision for the
promotion of labor is as clear as it is necessary. The goal is to position the worker on
an equal footing with the management-with all its power and influence-in
negotiations for the advancement of its interests and the protection of its rights. Under
the ideology of social justice, the law is bending endlessly to satisfy the needs of the
working class on the moral basis that those with less privilege in life should have
more rights in law.
If the Court were to follow the line of reasoning of the plaintiff, it would be
convenient for the management to delay the resolution of labor disputes, the workers'
grievances in particular, and to hide under the pretext of their officers being "on
leave" to avoid being caught within the 5-day time limit of the CBA. If this is
permitted, the employees will suffer great injustice because they will inevitably be at
the mercy of their boss. That could not have been the purpose of the particular section
of the CBA, far less the benign policy that underlies our labor laws.