Almagro vs. Philippine Airlines, Inc.

The doctrines of conclusiveness of judgment and stare decisis bar the relitigation of the issue of who participated in the illegal 1998 PAL strike, as prior final Supreme Court decisions have already established that the act of signing the company's return-to-work logbook after the prescribed deadline is conclusive evidence of participation in the said strike and defiance of the return-to-work order.

The case originated from a major labor dispute in the 1990s between Philippine Airlines, Inc. (PAL) and the Airline Pilots Association of the Philippines (ALPAP), the exclusive bargaining agent for PAL's commercial pilots. In response to alleged unfair labor practices by PAL, ALPAP staged a strike in June 1998, which was later declared illegal by the Secretary of Labor and Employment after the union defied a return-to-work order, leading to the mass termination of participating pilots.

• On December 9, 1997, the Airline Pilots Association of the Philippines (ALPAP) filed a notice of strike against Philippine Airlines, Inc. (PAL), and the DOLE Secretary assumed jurisdiction over the dispute on December 23, 1997.
• Despite the assumption of jurisdiction, ALPAP commenced a strike on June 5, 1998.
• On June 7, 1998, the DOLE Secretary issued a return-to-work order, directing all striking officers and members of ALPAP to report back to work by June 9, 1998.
• The strike continued, and on June 26, 1998, striking ALPAP members, including the petitioners in this case, attempted to return to work by signing a PAL security logbook titled "Return to Work Returnees/Compliance."
• PAL refused to accept the returning employees, stating that the deadline imposed by the return-to-work order had already lapsed.
• The DOLE Secretary subsequently declared the strike illegal and ruled that all officers and members who participated had lost their employment status; this was upheld by the Supreme Court in a prior case (G.R. No. 152306).
• Petitioners, who were former senior pilots of PAL, filed consolidated complaints for illegal dismissal, arguing they were on approved official leaves during the strike period and could not have participated in it.
• In a separate but related case, Airline Pilots Association of the Philippines v. Philippine Airlines, Inc. (G.R. No. 168382), the Supreme Court had already declared that the PAL security logbook was crucial evidence identifying the pilots who defied the return-to-work order.

• Petitioners argued that their signatures on the PAL security logbook were not admissions of participation in the strike but were merely an attempt to regain their employment.
• They contended that the return-to-work order was addressed only to striking officers and members, and since they were on approved official leave, they were not strikers and the order did not apply to them.
• Petitioners claimed it was legally impossible for them to have engaged in a strike because their work stoppage was with PAL's consent, as evidenced by their approved leaves.
• They asserted that they are not bound by the ruling in the Airline Pilots case under the doctrines of res judicata or stare decisis because they were not parties to that case and the evidence presented was different.
• They maintained that the conclusions of the Labor Arbiter and the NLRC were based on mere conjectures and that the photographic evidence presented by PAL was highly suspect.

• PAL argued that the petition was procedurally defective and raised factual issues that are beyond the scope of a Rule 45 petition for review.
• The company asserted that the Court of Appeals' Amended Decision was correct and well-supported by established facts, law, and jurisprudence.
• PAL maintained that its refusal to accept the petitioners who attempted to return to work on June 26, 1998, long after the deadline, was lawful and justified.
• The core of PAL's argument was that the petitioners are bound by the findings in the final and executory Airline Pilots case, which held that the signatories in the PAL security logbook were the ones who participated in the strike and defied the Secretary's return-to-work order.

• Procedural Issues:
  • Whether the Court of Appeals correctly determined that the NLRC did not commit grave abuse of discretion in affirming the Labor Arbiter's dismissal of the petitioners' complaints.
• Substantive Issues:
  • Whether the petitioners are bound by prior Supreme Court rulings which held that signing the PAL security logbook after the return-to-work deadline constituted conclusive proof of participation in the illegal strike, thereby justifying their dismissal.

• Procedural:
  • The Supreme Court held that its role in a Rule 45 review of a labor case is to determine the legal correctness of the Court of Appeals' decision, specifically whether the CA correctly determined the presence or absence of grave abuse of discretion by the NLRC. The Court found that the CA did not err, as the NLRC's decision was supported by substantial evidence and was consistent with established jurisprudence, thus precluding any finding of grave abuse of discretion.
• Substantive:
  • The petition was denied. The Court ruled that the doctrines of conclusiveness of judgment (a concept under res judicata) and stare decisis are applicable. The issue of who participated in the illegal strike and defied the return-to-work order was already conclusively settled in the Airline Pilots case, which identified the signatories of the PAL logbook as the defiant strikers. Since the petitioners admittedly signed this logbook, they are bound by this prior factual and legal determination. The Court found a substantial identity of parties and issues between this case and previous related cases, making the precedents binding.

• Res Judicata (Conclusiveness of Judgment) — This doctrine bars the relitigation of any right, fact, or matter in issue that was directly adjudicated or necessarily involved in a prior action before a competent court. In this case, it was applied to prevent the petitioners from re-arguing the factual issue of their participation in the strike, as the Supreme Court in Airline Pilots had already conclusively determined that signing the PAL logbook after the deadline identified the participants who lost their employment status.
• Stare Decisis — This principle dictates that courts will adhere to precedents and not unsettle things that have already been established, meaning that a conclusion reached in one case should be applied to subsequent cases where the facts are substantially the same. The Court applied this doctrine because the petitioners' situation and arguments were substantially identical to those raised in previous cases like Airline Pilots, Rodriguez, and Ahmee, all of which held that signing the logbook after the deadline justified dismissal.
• Grave Abuse of Discretion — This refers to a judgment exercised in a capricious, whimsical, arbitrary, or despotic manner, which is tantamount to a lack of jurisdiction. The Court used this standard to evaluate the NLRC's decision and concluded that the NLRC did not commit grave abuse of discretion because its ruling was based on substantial evidence (the logbook) and was in accord with binding jurisprudence.

• "Time and again, the Court has held that it is a very desirable and necessary judicial practice that when a court has laid down a principle of law as applicable to a certain state of facts, it will adhere to that principle and apply it to all future cases in which the facts are substantially the same. Stare decisis et non quieta movere. Stand by the decisions and disturb not what is settled. Stare decisis simply means that for the sake of certainty, a conclusion reached in one case should be applied to those that follow if the facts are substantially the same, even though the parties may be different.

• Airline Pilots Association of the Philippines v. Philippine Airlines, Inc. (G.R. No. 168382) — Cited as the controlling precedent which established that the PAL security logbook was the "crucial and vital piece of evidence" that identified the specific pilots who defied the return-to-work order and consequently lost their employment status.
• Rodriguez v. Philippine Airlines, Inc. (G.R. Nos. 178501 & 178510) — Referenced to demonstrate the application of res judicata (conclusiveness of judgment) to other pilots in a similar situation, establishing that individual union members are bound by the outcome of cases involving their union on the same core issue.
• Montoya v. Transmed Manila Corporation (G.R. No. 183329) — Used to define the limited scope of a Rule 45 review in labor cases, which focuses on whether the Court of Appeals correctly determined the presence or absence of grave abuse of discretion by the NLRC.
• Romeo N. Ahmee, et al. v. PAL (G.R. No. 180152) — Mentioned as another strong precedent where the Court affirmed that signatures on the same PAL logbook established the employees' participation in the illegal strike, reinforcing the application of stare decisis.

• Rule 45, Rules of Court — This rule governs the filing of a petition for review on certiorari with the Supreme Court, which was the procedural remedy availed by the petitioners.
• Rule 65, Rules of Court — This rule on special civil actions for certiorari was the basis for the petitioners' challenge of the NLRC decision before the Court of Appeals, and its standards (i.e., grave abuse of discretion) were central to the Supreme Court's analysis.
• Section 47, Rule 39, Rules of Civil Procedure — This provision outlines the effects of judgments and final orders and is the procedural basis for the doctrine of res judicata, particularly the concept of conclusiveness of judgment applied by the Court.