Week 3 Coverage Table
The table below mirrors the workbook's assigned cases for Week 3 and links each item to its digest page.
Class. records how the case actually stands to the subtopic it was assigned under — DIRECT (the Court squarely applies the doctrine), ANALOGOUS (it decides the point under a different provision or doctrine), REJECTED (the Court found the doctrine not established), INCIDENTAL (the doctrine is mentioned but the disposition rests elsewhere). Reciting a REJECTED case as if it were DIRECT inverts the holding.
| # | Assigned Case | Topic/Subtopic | Class. | Digest |
|---|---|---|---|---|
| 1 | Zialcita v. Philippine Air Lines, Case No. RO4-3-3398-76, February 20, 1977 | 6.a — Special groups of employees: women (Arts. 130, 132-136, Labor Code) | DIRECT |
On the source. Zialcita is a decision of the Office of the President on appeal from the Secretary of Labor — not of the Supreme Court — and its full text is not on lawphil or the SC E-Library. The digest quotes it from the Supreme Court's verbatim reproduction in Philippine Telegraph and Telephone Company v. NLRC, G.R. No. 118978, May 23, 1997. The workbook's own link audit flags this entry as having no reliable link.
On the outline. The workbook lists persons with disabilities twice — as item 6.g and again as item 6.i — both under R.A. No. 7277 as amended. Treat them as one item.
Recitation Map
One line per case — what it is for, and the categorical holding.
| Case | What it is for | Categorical holding |
|---|---|---|
| Zialcita v. PAL | Whether the ban on stipulations against marriage reaches "special" occupations | It does — "Article 136 is not intended to apply only to women employed in ordinary occupations"; absent the safety standards old Art. 132 contemplates, a no-marriage rule for flight attendants is "patently illegal" |
Study Notes
Read Zialcita for the structure of the argument, not just the result. The employer's defense was not that no-marriage clauses are lawful in general, but that flight attendants are a special class whose occupation justifies one. The ruling refuses that move twice over: first textually, because Art. 136 (now Art. 134) draws no distinction between ordinary and special occupations and "should have categorically expressed so" had one been intended; and second practically, because the companion provision old Art. 132 (now Art. 130) makes any occupation-based accommodation depend on safety and health standards the Secretary of Labor must first issue — and none had been.
Note the renumbering before reciting. Under DOLE Department Advisory No. 01, s. 2015, the women's provisions the syllabus assigns were renumbered: old Art. 132 → Art. 130, and old Art. 136 → Art. 134. The workbook's own heading, "Arts. 130 and 132-136," mixes the new number with the old range.
Where this connects. Zialcita is the ancestor of the Bona Fide Occupational Qualification line the class already met in Week 1 — Duncan v. Glaxo and Yrasuegui v. PAL, both of which upheld employer standards. Zialcita marks the other side of the line: a policy aimed at marital status alone, unsupported by any issued standard, is not a BFOQ. The Supreme Court's own adoption of it in PT&T v. NLRC is what makes it citable, and PT&T is the case to reach for when the professor asks for Supreme Court authority.