G.R. No. 85985 August 13, 1993

FACTS:

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.

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 13^th 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 13^th 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.