Case Name: PAL v.

ALPAP
G.R. Number: 200088
Topic: Labor Arbiter Author: Alec Vega
Doctrine:
To determine whether a claim for damages is cognizable by the LA, the reasonable
connection rule has been established which essentially states that the claim for damages
must have reasonable causal connection with any of the claims provided for in Art 224. A
money claim is within the jurisdiction of the LA if there is a reasonable causal connection
between the claim asserted and employee-employer relations. Absent such link the
complaint is within the province of the regular courts.
Facts:
Respondent filed with DOLE a notice of strike alleging that PAL commited ULP. The SOLE
assumed jurisdiction over the dispute and prohibited ALPAP to strike.
Despite the prohibition, respondent staged a strike and a return-to-work order was issued
by the SOLE but respondent defied the same. The SOLE declared the strike illegal and
ordered the termination of the officers who participated in the strike.
To determine whether a claim for damages is cognizable by the LA, the reasonable
connection rule has been established which essentially states that the claim for damages
must have reasonable causal connection with any of the claims provided for in Art 224. A
money claim is within the jurisdiction of the LA if there is a reasonable causal connection
between the claim asserted and employee-employer relations. Absent such link the
complaint is within the province of the regular courts.
In the instant case, the court agrees with petitioner that its claim has reasonable connection
with its employer-employee relationship with the respondents as petitioner’s cause of
action is not grounded on mere acts of quasi-delict. It arose from the illegal strike and acts
committed during it which were in turn closely related and intertwined with the
respondents allegations of ULP.
Since the loss and injury from which PAL seeks compensation have reasonable causal
connection with the alleged acts of ULP, a claim provided for in Art 224, the question of
damages becomes a labor controversy and is therefore an employment relationship
dispute.
Thus, it is the LA and NLRC which have jurisdiction not the regular courts.

The CA and SC upheld the SOLE’s resolution and the case attained finality.

8 months later, PAL filed a complaint before the LA for damages against the respondent
alleging that on the second day of the illegal strike, its striking pilots abandoned three
aircrafts and because of such abandonment the passengers were stranded and made PAL
liable for expenses.

The LA dismissed the complaint ruling that it had not jurisdiction to resolve the issue on
damages and that the SOLE did not certify the controversy for compulsory arbitration to
the NLRC nor did the parties agree to refer the same to voluntary arbitration hence the
jurisdiction of all issues arising from the controversy was left with the SOLE.

The NLRC affirmed the LA decision.

The CA affirmed the dismissal on the ground of lack of jurisdiction on the ground that the
exclusive jurisdiction over PAL’s claim for damages lies with the regular courts and not the
SOLE.
Issue: W/N the LA has jurisdiction over the money claims of PAL?
Held/Ratio:
Yes

Art 224 of the Labor Code as amended by RA 6715 provides that the LA and the NLRC have
jurisdiction to resolve cases involving claims for damages arising from employer-employee
relationship including actions for damages arising from a labor strike.

It is settled, however, that not every controversy or money claim by an employee against
the employer or vice-versa falls within the jurisdiction of the labor arbiter as civil disputes
are cognizable by regular courts.