In labor disputes, procedural rules dictate how parties can challenge decisions. The Supreme Court clarified that a motion for reconsideration is not a prohibited second motion when a tribunal substantially reverses its initial ruling. This means that if a court or body like the National Labor Relations Commission (NLRC) changes its stance on a key issue, the aggrieved party has the right to seek reconsideration of that reversal, even if they had previously filed a motion on other grounds. This ruling ensures fairness and allows parties to address significant shifts in legal determinations, preventing unjust outcomes due to procedural technicalities.

From Downsizing to Dispute: Examining Retirement Benefits and Due Process at Philippine Airlines

Angelito Cristobal, a pilot for Philippine Airlines (PAL), sought to retire after working for EVA Air under an approved leave of absence during PAL’s downsizing program. A dispute arose when PAL informed Cristobal that he had lost his employment status. Cristobal then filed a complaint with the NLRC. The initial Labor Arbiter decision favored Cristobal, finding his dismissal illegal and awarding retirement pay, damages, and attorney’s fees. However, this ruling underwent significant changes through subsequent motions and decisions, raising questions about the proper application of retirement benefits and the adherence to procedural rules.

The NLRC initially affirmed the Labor Arbiter’s decision but reduced the moral and exemplary damages. Both Cristobal and PAL filed motions for reconsideration. The NLRC then substantially altered its position. It deleted the damages and significantly reduced Cristobal’s retirement benefits, relying on a previous Supreme Court ruling, Philippine Airlines, Inc. vs. Airline Pilots Association of the Philippines, which stated that Article 287 of the Labor Code does not apply to PAL pilots retiring before age 60 under the 1967 PAL-ALPAP Retirement Plan. Cristobal then filed a motion for reconsideration, arguing that the NLRC had erroneously considered benefits from a separate investment plan. The NLRC denied this motion, deeming it a prohibited second motion for reconsideration.

Cristobal elevated the case to the Court of Appeals (CA), but the CA dismissed his petition, agreeing with the NLRC that his motion was indeed a prohibited second motion and thus filed out of time. This dismissal prompted Cristobal to seek recourse with the Supreme Court, arguing that his motion addressed a completely new issue raised in the NLRC’s amended decision. At the heart of the matter was whether Cristobal’s motion for reconsideration concerning the reduction of retirement benefits was a prohibited second motion, or a legitimate challenge to a substantially altered decision.

The Supreme Court, in resolving the issue, referenced Rule VII, Section 15 of the National Labor Relations Commission Rules of Procedure. This rule generally prohibits entertaining more than one motion for reconsideration from the same party. However, the Court emphasized that this prohibition applies to the same judgment or final resolution, not to a situation where a decision substantially reverses a prior determination. As highlighted in Poliand Industrial Ltd. v. National Development Co., a motion seeking review of a resolution that delves into a new issue for the first time is not considered a prohibited second motion for reconsideration.

Building on this principle, the Court cited Solidbank Corp. v. Court of Appeals, where an amended decision superseding the original allows for a new motion for reconsideration.

The Amended Decision is an entirely new decision which supersedes the original decision, for which a new motion for reconsideration may be filed again.

Similarly, in Barba v. Liceo De Cagayan University, the Court held that the prohibition against a second motion for reconsideration applies only when the same party assails the same judgment. Here, the NLRC’s May 31, 2011 Decision significantly modified its earlier decision, entitling Cristobal to seek reconsideration.

The Supreme Court underscored that the CA erred in finding Cristobal’s petition for certiorari as filed out of time. Furthermore, the Court addressed the CA’s dismissal based on the purported failure to attach necessary records. Citing Wack Wack Golf & Country Club v. National Labor Relations Commission, the Court reiterated that subsequent substantial compliance with procedural rules may warrant relaxation of said rules in the interest of justice. This principle allows for flexibility when the core issue is clear and the missing documents do not impede a fair resolution.

In light of these considerations, the Supreme Court reversed and set aside the CA’s resolutions, directing the CA to reinstate Cristobal’s petition for certiorari. The Supreme Court noted that a key issue, the inclusion of the PAL Pilots Retirement Benefit Plan in calculating retirement benefits, remained unaddressed. To ensure a just resolution, the Court deemed it necessary to remand the case to the CA, allowing both parties to fully discuss this crucial aspect.

FAQs

What was the key issue in this case?	The central issue was whether Cristobal’s motion for reconsideration, challenging the reduction of his retirement benefits, constituted a prohibited second motion for reconsideration under NLRC rules.
What did the Supreme Court decide?	The Supreme Court ruled that Cristobal’s motion was not a prohibited second motion, as it addressed a substantial change in the NLRC’s decision regarding his retirement benefits.
Why did the Court of Appeals initially dismiss Cristobal’s petition?	The Court of Appeals dismissed the petition, agreeing with the NLRC that Cristobal’s motion was a prohibited second motion, making the petition for certiorari filed out of time.
What is the significance of the PAL Pilots Retirement Benefit Plan in this case?	The inclusion or exclusion of the PAL Pilots Retirement Benefit Plan in the calculation of Cristobal’s total retirement benefits is a contested issue that the Supreme Court directed the Court of Appeals to address.
What happens next in this case?	The case has been remanded to the Court of Appeals, which must now reinstate the petition for certiorari and conduct further proceedings to address the unresolved issues.
What is the rule regarding second motions for reconsideration?	Generally, the NLRC Rules of Procedure prohibit a second motion for reconsideration from the same party, but this does not apply when the tribunal renders a decision substantially reversing itself.
What prior cases influenced the Supreme Court’s decision?	The Supreme Court relied on cases like Poliand Industrial Ltd. v. National Development Co., Solidbank Corp. v. Court of Appeals, and Barba v. Liceo De Cagayan University to support its ruling.
What was the basis for the NLRC’s reduction of Cristobal’s retirement benefits?	The NLRC based its reduction on a previous Supreme Court ruling (Philippine Airlines, Inc. vs. Airline Pilots Association of the Philippines) and the 1967 PAL-ALPAP Retirement Plan.
How does this ruling impact other labor disputes?	This ruling clarifies that parties are entitled to seek reconsideration when labor tribunals substantially change their decisions, ensuring fairness and due process.

This case underscores the importance of procedural fairness in labor disputes and clarifies the circumstances under which a motion for reconsideration is permissible. The Supreme Court’s decision ensures that parties have an opportunity to address significant changes in legal determinations, preventing unjust outcomes due to procedural technicalities.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ANGELITO L. CRISTOBAL vs. PHILIPPINE AIRLINES, INC., AND LUCIO TAN, G.R. No. 201622, October 04, 2017