G.R. No. 85985 August 13, 1993
In 1985, PAL completely revised its 1966 Code of Discipline. The Code was circulated among the employees and was immediately implemented, and some employees were forthwith subjected to the disciplinary measures embodied therein.
PALEA filed a complaint before the NLRC for unfair labor practice due to arbitrary implementation of PAL’s Code of Discipline without notice and prior discussion with Union by Management under Article 249 and Article 253 of the Labor Code. The Union also alleged that the copies of the Code did not conform with the requirements of sufficient publication and was circulated in limited numbers. It argues that PAL should discuss the substance of the Code with PALEA and that employees dismissed under the Code be reinstated and their cases subjected to further hearing.