Philippine Airlines Vs Ligan Case Digest

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PHILIPPINE AIRLINES vs LIGAN Case Digest

PHILIPPINE AIRLINES, INC. v. ENRIQUE LIGAN, et al.


G.R. No. 146408, 30 April 2009

FACTS: Enrique Ligan, et al. and the other respondents were employees of Synergy
Services Corporation (Synergy) which provides manpower for Philippine Airlines. It was
later discovered that Synergy is a labor-only contractor. They were dismissed by
Philippine Airlines on several grounds, one of which is in the guise of retrenchment. The
legality of the dismissal of the Ligan, et al. has been pending before the Court of
Appeals.

Philippine Airlines paid the wages of the Ligan, et al. but contested the employment
status of Roque Pilapil for he is already terminated and Benedicto Auxtero who signed
the ―Release and Quitclaim and Waiver‖. Philippine Airlines therefore pleads to the
court to reconsider its first Decision on the payment of wages and benefits.

ISSUE: Whether or not the Supreme Court shall overrule its first decision regarding the
grant of wages and benefits to Ligan, et al.

HELD: In light of these recent manifestations-informations of the parties, the Court finds
that a modification of the Decision is in order, the claims with respect to Pilapil and
Auxtero having been deemed extinguished even before the promulgation of the
Decision. That Pilapil was a regular employee yields to the final finding of a valid
dismissal in the supervening case involving his own misconduct, while Auxtero’s
attempt at forum-shopping should not be countenanced.

IN ALL OTHER RESPECTS, the Court finds no sufficient reason to deviate from its
Decision, but proceeds, nonetheless, to clarify a few points. While this Court’s Decision
ruled on the regular status of Ligan, et al., it must be deemed to be without prejudice to
the resolution of the issue of illegal dismissal in the proper case.

Notably, subject of the Decision was Ligan, et al.’s complaints for regularization and
under-/non-payment of benefits. The Court did not and could not take cognizance of the
validity of the eventual dismissal of Ligan, et al. because the matter of just or authorized
cause is beyond the issues of the case. That is why the Court did not order
reinstatement for such relief presupposes a finding of illegal dismissal in the proper
case which, as the parties now manifest, pends before the appellate court.

All told, the pending illegal dismissal case in CA-G.R. SP No. 00922 may now take its
course. The Court’s finding that Ligan, et al. are regular employees of PAL neither
frustrates nor preempts the appellate court’s proceedings in resolving the issue of
retrenchment as an authorized cause for termination. If an authorized cause for
dismissal is later found to exist, PAL would still have to pay Ligan, et al. their
corresponding benefits and salary differential up to June 30, 1998. Otherwise, if there is
a finding of illegal dismissal, an order for reinstatement with full backwages does not
conflict with the Court’s declaration of the regular employee status of Ligan, et al.

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