G.R. No. 142399. March 12, 2008
FACTS:
PAL and respondent PALEA entered into a CBA covering the period of 1986-1989. Part of said agreement required PAL to pay its rank and file employees 13th month and Christmas Bonus. In 1988, PAL releases a guideline which provides that those who have not yet achieved regular status by the cut-off date, 30 April 1988 shall not be eligible for 13th month.
PALEA filed a labor complaint for unfair labor practices asserting that all employees of PAL, regular or non-regular, must be paid their 13th month pay. It also argues that the guideline is in contravention of the Collective Bargaining Agreement (CBA) entered into by petitioner PAL and respondent PALEA.
PAL asserts that it did not deny their 13th month pay considering they receive said mandatory bonus in the form of the Christmas Bonus which is in compliance with Presidential Decree No. 851.