Airline Pilots Association of the Philippines v. Philippine Airlines, Inc.
REITERATIONFacts
The Antecedents: This case originated from a labor dispute between Philippine Airlines, Inc. (PAL) and the Airline Pilots Association of the Philippines (ALPAP), the bargaining agent for PAL pilots. ALPAP filed a notice of strike in December 1997, alleging unfair labor practices by PAL. The Department of Labor and Employment (DOLE) Secretary assumed jurisdiction over the dispute, prohibiting strikes and lockouts and ordering the parties to submit position papers. Despite this, ALPAP proceeded with a strike on June 5, 1998, prompting a return-to-work order from the DOLE on June 7, 1998. PAL refused to accept the pilots back immediately, leading ALPAP to file a complaint for illegal lockout. Procedural History: The DOLE Secretary consolidated the illegal lockout case with the original strike case. On June 1, 1999, the DOLE declared ALPAP's strike illegal and stated that participating officers and members had lost their employment status, while dismissing the illegal lockout complaint. ALPAP's motion for reconsideration was denied, and its subsequent petition for certiorari with the Court of Appeals (CA) was also denied. This Court affirmed the CA's decision, and the ruling became final and executory on August 29, 2002. Subsequently, ALPAP filed motions with the DOLE Secretary requesting a proceeding to determine which members actually participated in the strike and should be deemed to have lost employment, citing a recommendation from the International Labour Organization. The Acting DOLE Secretary and later the DOLE Secretary merely noted these motions, citing the finality of the Supreme Court's judgment and the pendency of individual illegal dismissal cases before the National Labor Relations Commission (NLRC). ALPAP then filed a petition for certiorari with the CA, challenging the DOLE's refusal to act on its motions. The Petition: ALPAP filed a Petition for Review on Certiorari with this Court, assailing the CA's decision which found no grave abuse of discretion on the part of the DOLE Secretaries. ALPAP argues that the DOLE Secretaries erred in merely noting its motions, as the issues raised stemmed from the DOLE's assumption of jurisdiction and remained unresolved. It seeks a declaration of nullity for the assailed DOLE letters and requests a proceeding to determine who actually participated in the illegal strike and consequently lost their employment status. The core of ALPAP's argument is that the DOLE has a duty to resolve these issues, and the DOLE Secretaries' refusal to act constituted an abdication of duty and a denial of due process.
Issue(s)
Whether the Court of Appeals committed reversible error when it declared that the public respondent did not commit grave abuse of discretion amounting to lack and/or excess of jurisdiction when it refused to act on ALPAP’s motions and merely noted the same. Whether the Court of Appeals committed grave mistake in declaring that the June 1, 1999 Resolution of the Department of Labor and Employment has already taken up and resolved the issue of who among the ALPAP members are deemed to have lost their employment status.
Ruling
The petition is denied for lack of merit. The Decision of the Court of Appeals dated December 22, 2004 and Resolution dated May 30, 2005 in CA-G.R. SP No. 79686 are affirmed.
Ratio Decidendi
On the issue of whether the DOLE Secretary committed grave abuse of discretion by merely noting ALPAP's motions: The Supreme Court held that there was no grave abuse of discretion. The DOLE Secretary's action of merely noting ALPAP's motions was in due deference to a final and immutable judgment rendered by the Supreme Court. The DOLE Resolution declaring the strike illegal and pronouncing loss of employment status had been affirmed by the CA and subsequently by the Supreme Court, which became final and executory. To conduct the proceeding sought by ALPAP would entail reopening a final judgment, which is impermissible under the principle of immutability of judgments. The Court reiterated that once a decision has attained finality, it becomes immutable and unalterable, and nothing further can be done except to execute it. On the issue of whether the DOLE Resolution of June 1, 1999, had already resolved the issue of who among ALPAP members lost their employment status: The Supreme Court found that while the dispositive portion of the DOLE Resolution did not specifically enumerate names, it declared that strikers who failed to heed the return-to-work order were deemed to have lost their employment. The Court clarified that any ambiguity in a judgment can be clarified by reference to the body of the decision and the pleadings filed. The records showed that the DOLE Secretary declared loss of employment status based on participation in the illegal strike or defiance of the return-to-work order. Crucially, the logbook of returning pilots, signed by each of them, served as evidence of their compliance only on June 26, 1998, after the deadline. The complaint for illegal lockout was filed on behalf of these returnees, making the finding of no illegal lockout enforceable against them. Therefore, only those returning pilots were bound by the DOLE Resolution. The Court also noted that allegations of being on leave or abroad, which ALPAP raised late, were not presented during the pendency of the case before the DOLE, CA, or Supreme Court, and were raised only after the judgment became final, constituting a last-ditch effort to reopen the case. These defenses were not raised during the proceedings where ALPAP had ample opportunity to present its evidence and arguments, thus, it could not claim denial of due process.
Main Doctrine
A judgment that has attained finality is immutable and unalterable, and thus can no longer be modified in any respect, except for recognized exceptions. The DOLE Secretary, the Court of Appeals, and the Supreme Court all correctly deferred to the finality of the Supreme Court's resolution, refusing to reopen issues already passed upon.