Mr Y worked as an international flight steward for Philippine Airlines. He stood five feet and eight inches tall. Under PAL’s weight standards, his ideal weight was 166 pounds. Over the years, however, his weight repeatedly exceeded the airline’s limits. At one point, he weighed 215 pounds—49 pounds above the prescribed standard.

PAL did not immediately terminate him. Instead, the airline repeatedly gave him opportunities to lose weight. He was placed on leave, grounded from flight duties, required to undergo regular weight checks, and repeatedly reminded of the company’s weight standards. PAL even offered the assistance of its company physician.

The efforts stretched over several years. Despite numerous extensions and warnings, Mr Y failed to attain the required weight. In fact, there were periods when he gained additional weight rather than losing it. Eventually, after almost five years of leniency, PAL terminated his employment.

Mr Y challenged his dismissal. According to him, obesity is a medical condition and cannot be treated as misconduct. He argued that his weight did not prevent him from performing his duties. He also claimed that PAL discriminated against him because other overweight employees were allegedly promoted rather than disciplined. Was PAL justified in terminating his employment?

Yes. The Supreme Court began by recognizing that PAL’s weight standards were not mere workplace rules. They were continuing qualifications for the position of flight attendant. In other words, maintaining the required weight was part of remaining qualified for the job itself.

The Court emphasized that airline companies are common carriers. As such, they are legally required to exercise extraordinary diligence for the safety of their passengers. Flight attendants are not merely servers of food and drinks. Their most important responsibility is ensuring passenger safety, particularly during emergencies and evacuations.

According to the Court, agility, mobility, stamina, and the ability to move quickly through narrow aircraft aisles are essential components of the job.

For this reason, the Court held that PAL’s weight standards constituted a valid bona fide occupational qualification. The standards were reasonably related to flight safety and to the proper performance of a flight attendant’s duties.

The Court also rejected Mr Y’s claim that obesity automatically constituted a disease that excused compliance. The evidence showed that he had successfully reduced his weight in the past and that PAL had repeatedly extended assistance and opportunities for him to comply. The Court concluded that his inability to maintain the required weight did not excuse his failure to satisfy the continuing qualifications of his position.

As for discrimination, the Court found that Mr Y failed to prove that other allegedly overweight employees were similarly situated or that they had received preferential treatment under comparable circumstances. Mere allegations were not enough.

Accordingly, the Supreme Court upheld the legality of his dismissal.

There was, however, one important qualification. The Court noted that Mr Y was not dismissed for dishonesty, fraud, theft, or any form of serious misconduct. Neither did his violation reflect upon his moral character. Considering his years of service, the Court awarded him separation pay as an act of equity and social justice.

Yrasuegui v. Philippine Airlines. G.R. No. 168081, October 17, 2008