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ARMANDO G. YRASUEGUI v. PHILIPPINE AIRLINES

FACTS:

Armando G. Yrasuegui, a former international flight steward of Philippine Airlines, Inc. (PAL), was dismissed from his job due to his failure to adhere to the company's weight standards. Yrasuegui had a history of weight problems dating back to 1984 and had gone on extended leave without pay to address his weight concerns. However, his weight problem recurred, and he failed to comply with the weight requirement despite repeated checks and reminders. Yrasuegui made a commitment to lose weight but still remained overweight. PAL served him a Notice of Administrative Charge for violation of company standards on weight requirements, and despite claiming that his violation had already been condoned and alleging discrimination, he was formally dismissed from his job.

The petitioner was employed as a flight steward by Philippine Airlines (PAL). PAL implemented weight standards for its employees, and the petitioner consistently failed to meet the prescribed weight standards. After several years of leniency, PAL terminated the petitioner's services. The petitioner filed a complaint for illegal dismissal, which was ruled in his favor by the Labor Arbiter. However, both parties appealed to the National Labor Relations Commission (NLRC). The NLRC affirmed the Labor Arbiter's decision, stating that obesity is a disease and there was no intentional defiance or serious misconduct on the part of the petitioner. The Court of Appeals (CA) reversed the NLRC's decision, holding that the weight standards of PAL are reasonable and the petitioner was legally dismissed for repeatedly failing to meet the prescribed weight standards. The CA emphasized that the weight standards are a bona fide occupational qualification. The petitioner filed a petition for review with the Supreme Court.

The petitioner, a cabin attendant for the respondent airline company, was hired in 1970 and was subsequently dismissed due to his obesity. The respondent argued that the petitioner's weight exceeded the limits prescribed for his position, posing a risk to passenger safety and health. The petitioner filed a complaint for illegal dismissal and discrimination, claiming unjust dismissal and unequal treatment compared to other overweight cabin attendants. The labor arbiter ruled in favor of the petitioner, but the NLRC reversed the decision on appeal. The CA upheld the NLRC's decision, leading the petitioner to file a petition for review with the Supreme Court.

ISSUES:

  1. Whether or not the Court of Appeals gravely erred in holding that petitioner's obesity can be a ground for dismissal under paragraph (e) of Article 282 of the Labor Code of the Philippines.

  2. Whether or not the Court of Appeals gravely erred in holding that petitioner's dismissal for obesity can be predicated on the "bona fide occupational qualification (BFOQ) defense".

  3. Whether or not the Court of Appeals gravely erred in holding that petitioner was not unduly discriminated against when he was dismissed while other overweight cabin attendants were either given flying duties or promoted.

  4. Whether or not the Court of Appeals gravely erred when it brushed aside petitioner's claims for reinstatement and wages allegedly for being moot and academic.

RULING:

  1. The obesity of the petitioner is a ground for dismissal under Article 282(e) of the Labor Code.

  2. The dismissal of the petitioner can be predicated on the bona fide occupational qualification defense.

  3. The petitioner failed to substantiate his claim that he was discriminated against by PAL.

  4. The claims of the petitioner for reinstatement and wages are moot.

  5. Petitioner is entitled to separation pay equivalent to one-half (1/2) month's pay for every year of service.

PRINCIPLES:

  1. The continuing qualification standards of an employer as a basis for dismissal can constitute "other causes analogous" as stated in Article 282(e) of the Labor Code.

  2. Bona fide occupational qualification (BFOQ) as a valid defense does not necessitate supporting statutory provision if grounded on reasonable necessity connected to the job.

  3. The equal protection clause is not typically invoked against acts of private individuals unless there is governmental interference.

  4. Compliance with return-to-work orders is essential for claims of backwages and reinstatement.

  5. Exceptionally, separation pay may be granted as an act of social justice or based on equity for legally dismissed employees if the dismissal was not for serious misconduct and does not reflect on the moral character of the employee.