In Almagro v. Philippine Airlines, the Supreme Court reiterated that employees participating in an illegal strike and defying a return-to-work order lose their employment status. The Court emphasized the importance of adhering to final and executory judgments and the principle of stare decisis, preventing the relitigation of issues already decided in previous cases involving similar facts and parties. This ruling underscores the serious consequences of disobeying lawful orders in labor disputes and reaffirms the finality of court decisions.

When Pilots Ground Themselves: Illegal Strikes and the Price of Defiance

This case involves former senior pilots of Philippine Airlines, Inc. (PAL) who were dismissed after participating in an illegal strike. The pilots, members of the Airline Pilots Association of the Philippines (ALPAP), joined a strike that defied a return-to-work order issued by the Secretary of Labor and Employment. When they attempted to return to work after the deadline, PAL refused to reinstate them, leading to a series of legal battles. The central legal question is whether these pilots, by participating in the illegal strike and defying the return-to-work order, forfeited their employment status, especially considering prior Supreme Court rulings on the same labor dispute.

The Supreme Court anchored its decision on two key legal principles: conclusiveness of judgment (res judicata) and stare decisis. Conclusiveness of judgment, as embodied in Section 47, Rule 39 of the Rules of Civil Procedure, prevents the relitigation of issues already decided in a previous case between the same parties or their privies. The Court noted that the issue of who participated in the illegal strike and defied the return-to-work order had already been conclusively settled in Airline Pilots Association of the Philippines v. Philippine Airlines, Inc. (Airline Pilots). The pilots’ signatures in PAL’s logbook, indicating their attempt to return to work after the deadline, served as evidence of their participation in the strike and defiance of the order.

A review of the records reveals that in [the strike case], the DOLE Secretary declared the ALPAP officers and members to have lost their employment status based on either of two grounds, viz.: their participation in the illegal strike on June 5, 1998 or their defiance of the return-to-work order of the DOLE Secretary. The records of the case unveil the names of each of these returning pilots. The logbook with the heading “Return to Work Compliance/Returnees” bears their individual signature signifying their conformity that they were among those workers who returned to work only on June 26, 1998 or after the deadline imposed by DOLE.

The Court found that even though the pilots argued they were on official leave during the strike, this defense was raised too late and had already been addressed in previous cases. Thus, the principle of res judicata applied, barring them from relitigating the issue. Further, the Court invoked the principle of stare decisis et non quieta movere, which means “to adhere to precedents, and not to unsettle things which are established.” This principle mandates that courts should follow precedents in similar cases to ensure certainty and stability in judicial decisions.

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.

The Court highlighted that the factual circumstances and arguments raised by the pilots were substantially similar to those in previous cases, including Rodriguez v. Philippine Airlines, Inc. and Ahmee, et al. v. PAL. Therefore, the principle of stare decisis required the Court to adhere to its prior rulings. The pilots’ attempt to distinguish their case based on the evidence presented was unsuccessful, as the Court found the PAL security logbook to be a crucial and consistent piece of evidence establishing their participation in the strike and defiance of the return-to-work order.

The Supreme Court emphasized that participation in an illegal strike and defiance of a return-to-work order are valid grounds for termination. The Labor Code of the Philippines recognizes the right of employees to strike, but this right is not absolute. Strikes must be conducted in accordance with the law, and employees must comply with lawful orders issued by the Department of Labor and Employment. Failure to do so can result in the loss of employment status. This ruling serves as a stern reminder to employees and labor unions to adhere to legal processes and respect lawful orders in labor disputes. It underscores the importance of seeking redress through proper channels and complying with return-to-work orders to avoid the severe consequence of termination.

The Court’s decision in Almagro v. Philippine Airlines reaffirms the finality of judgments and the binding nature of precedents. It clarifies that issues already decided in previous cases cannot be relitigated, and courts must adhere to established principles of law. This promotes stability and predictability in the legal system, ensuring that similar cases are treated consistently. For employers, this ruling provides assurance that they can rely on established legal principles and prior court decisions in managing labor disputes. It reinforces their right to terminate employees who participate in illegal strikes and defy return-to-work orders. However, it also emphasizes the importance of following due process and ensuring that terminations are based on substantial evidence. For employees, this ruling serves as a cautionary tale. It highlights the serious consequences of participating in illegal strikes and defying lawful orders. It underscores the importance of seeking legal advice and complying with legal processes to protect their rights. Employees should also be aware of the binding nature of prior court decisions and avoid relitigating issues that have already been decided. This ensures that their employment rights are protected while promoting a stable labor environment.

FAQs

What was the key issue in this case?	The key issue was whether the pilots’ participation in an illegal strike and defiance of a return-to-work order justified their dismissal, given prior Supreme Court rulings on the same labor dispute.
What is the significance of the PAL security logbook?	The PAL security logbook, containing the signatures of pilots attempting to return to work after the deadline, served as crucial evidence of their participation in the strike and defiance of the return-to-work order.
What is res judicata and how did it apply in this case?	Res judicata, or conclusiveness of judgment, prevents the relitigation of issues already decided in a previous case between the same parties or their privies. The Court ruled that the issue of the legality of the strike had already been settled.
What is stare decisis and why is it important?	Stare decisis is the principle of adhering to precedents, ensuring consistency and stability in judicial decisions. It was important here as the court had already ruled on similar facts.
Can employees on official leave participate in a strike?	Even if employees are on official leave, participating in an illegal strike and defying a return-to-work order can lead to termination, especially if the strike has been declared illegal and a return-to-work order has been issued.
What is a return-to-work order?	A return-to-work order is an order issued by the Department of Labor and Employment (DOLE) requiring striking employees to return to their jobs. Defiance can result in loss of employment status.
Who are considered parties or privies for res judicata?	Parties or privies include those with a substantial identity of interest, such as a union representing its members. This allows res judicata to apply even if all individuals were not named in the first case.
What should employees do if they disagree with a return-to-work order?	Employees who disagree with a return-to-work order should seek legal advice and comply with the order while pursuing legal remedies through proper channels. Defiance can result in severe penalties.

The Supreme Court’s decision in Almagro v. Philippine Airlines reinforces the importance of adhering to legal processes and respecting lawful orders in labor disputes. It serves as a reminder that the right to strike is not absolute and must be exercised within the bounds of the law. By upholding the principles of res judicata and stare decisis, the Court promotes stability and predictability in the legal system, ensuring that similar cases are treated consistently.

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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: Almagro, G.R. No. 204803, September 12, 2018