SC: Flying for work doesn’t always mean flying risk pay


Civil Aviation Authority of the Philippines (CAAP) personnel whose jobs require them to travel by air are not automatically entitled to flying risk pay if their duties are not directly related to flight operations, the Supreme Court (SC) has ruled.
In a decision penned by Associate Justice Henri Jean Paul Inting dated 21 January 2026, the SC En Banc upheld the Commission on Audit’s (COA) disallowance of P323,579.50 in flying risk pay granted to CAAP officials and employees whose duties were primarily managerial, administrative or financial.
Under Republic Act 776, or the Civil Aeronautics Act of the Philippines, licensed airmen and other authorized personnel required to make regular and frequent aerial flights in connection with their duties may receive flying risk pay equivalent to 50 percent of their salary, provided they complete at least four hours of flight time per month.
In 2011, CAAP granted the benefit to employees who met the four-hour requirement, including personnel who traveled by air to attend conferences, seminars, public hearings and inspections.
COA disallowed the payments, finding that the benefit was intended for personnel whose duties involved aerial and flight operations.
The recipients argued that the law covered not only “airmen” but also “other authorized personnel,” regardless of whether their duties were directly related to flight operations.
The SC disagreed.
It noted that RA 776 defines an “airman” as a pilot, mechanic, flight radio operator, aircraft crew member or a person responsible for inspecting, maintaining or repairing aircraft, all functions directly connected to aircraft operations.
The Court said “other authorized personnel” likewise refers to employees required to make regular and frequent aerial flights as part of their official flight-related duties.
Citing the Government Accounting and Auditing Manual, the SC said flying risk pay is limited to personnel whose duties are inherent in flight operations and does not cover employees who fly merely as passengers.
The Court found that the recipients’ air travel was incidental to their managerial, administrative or financial responsibilities rather than part of flight operations.