25/06/2025
The (SC) has affirmed a Court of Appeals (CA) ruling finding that Philippine Airlines, Inc. (PAL) did not sufficiently prove payment of salaries and 13th month pay to its former pilots. To prove salary payment through banks, the Court held that employers must show that the payroll was submitted to and received by the bank.
In a Decision penned by Chief Justice Alexander G. Gesmundo, the SC’s First Division remanded to the National Labor Relations Commission (NLRC) the labor claims of 18 former PAL pilots, to determine the exact amount and to make a detailed computation of the monetary benefits due to them.
It found that the Payroll Listing and 13th Month Pay Payroll Register presented by PAL were not sufficient proof of payment, as they did not provide proof of actual receipt of payment by the employees.
The case stemmed from a 1998 strike by 49 PAL pilots, who later filed a complaint with the NLRC against PAL alleging illegal dismissal, unfair labor practice, and non-payment of various monetary benefits such as salaries, allowances, and bonuses.
The Labor Arbiter dismissed the claims of illegal dismissal and unfair labor practice. As for the monetary claims, PAL presented payroll documents to prove payment, which were accepted by both the Labor Arbiter and the NLRC.
The CA, however, reversed the NLRC. stating that the documents presented by PAL were not sufficient proof of payment.
The SC affirmed the CA, emphasizing that payroll records and vouchers can only be considered strong proof of payment if they clearly show that the employees actually received the money and when the payment was made.
Read the full text of the Press Release at https://tinyurl.com/ac5kehbk.
Read the full text of the Decision at https://tinyurl.com/c4dpa3sj.
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