Vicente S. Almario v. Philippine Airlines

Summary

PAL employee Vicente Almario underwent expensive Airbus 300 training costing over P786,000 but resigned after only 8 months instead of the expected 3-year service period. PAL sued for reimbursement based on CBA provisions and unjust enrichment principles. The RTC initially ruled for Almario, finding no explicit reimbursement clause in the CBA. However, the Court of Appeals reversed, and the Supreme Court affirmed, holding that the CBA's age restriction provisions (freezing pilots at 57 due to 3-year training cost recovery period before mandatory retirement at 60) implicitly established the training cost reimbursement principle. The Court applied Article 22 of the Civil Code on unjust enrichment, ruling that Almario cannot retain the benefit of expensive training without compensating PAL for the unrecovered costs. The final reimbursement amount was P559,739.90 with legal interest.