G.R. No. 171212, August 4, 2014
INDOPHIL TEXTILE MILLS, INC., Petitioner, vs. ENGR. SALVADOR ADVIENTO, Respondent.

FACTS

Petitioner Indophil Textile Mills, Inc. hired respondent Engr. Salvador Adviento as a Civil Engineer on August 21, 1990. On August 7, 2002, respondent was diagnosed with Chronic Poly Sinusitis and moderate, severe and persistent Allergic Rhinitis. His doctor advised him to totally avoid house dust mite and textile dust. Respondent filed a complaint for illegal dismissal and monetary claims with the NLRC (NLRC Case No. RAB-III-05-5834-03), which was pending. Subsequently, respondent filed a Complaint with the RTC of Aparri, Cagayan, alleging he contracted the occupational disease due to petitioner’s gross negligence in failing to provide a safe, healthy, and workable environment. He detailed that his job required maintenance checks in a dye house area that was very hot, emitted foul chemical odor, and had dust issues, and that his recommendations for improvements (like roof insulation and office relocation) were rejected by management due to high cost. He prayed for moral, exemplary, and compensatory damages. Petitioner filed a Motion to Dismiss on grounds of lack of jurisdiction (arguing it fell under the Labor Arbiter’s exclusive jurisdiction under Article 217 of the Labor Code) and litis pendentia due to the pending NLRC case. The RTC denied the motion, ruling the action was based on quasi-delict. The CA affirmed the RTC’s jurisdiction and dismissed petitioner’s certiorari petition.

ISSUE

Whether the Regional Trial Court has jurisdiction over respondent’s complaint for damages anchored on petitioner’s alleged gross negligence in failing to provide a safe and healthy working environment.

RULING

Yes, the Regional Trial Court has jurisdiction. The Supreme Court applied the “reasonable causal connection rule.” While Article 217(a)(4) of the Labor Code grants Labor Arbiters jurisdiction over “[c]laims for actual, moral, exemplary and other forms of damages arising from employer-employee relations,” the Court found that respondent’s cause of action was based on quasi-delict or tort. The complaint alleged gross negligence on the part of petitioner in maintaining a hazardous workplace, which is a breach of the general duty to provide a safe environment, a obligation owed to its employees not merely by virtue of the employment contract but under the Civil Code. The claim for damages was grounded on a tortious act, and the employer-employee relationship was merely incidental. The existence of an employer-employee relationship does not automatically place such a claim under labor tribunal jurisdiction. The Court distinguished this from a claim for damages where the reasonable causal connection to the employer-employee relation is direct, such as those stemming from illegal dismissal or unfair labor practice. Since the cause of action was essentially a tort, jurisdiction properly lay with the regular courts. The pending NLRC case for illegal dismissal involved a different cause of action.