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MANILA ELECTRIC COMPANY v. ROSARIO GOPEZ LIM

FACTS:

Respondent Rosario G. Lim, also known as Cherry Lim, is an administrative clerk at the Manila Electric Company (MERALCO). In June 2008, an anonymous letter was posted at the door of the Metering Office of the Administration building of MERALCO, denouncing respondent's loyalty to the company and calling for her to leave. Copies of the letter were also inserted in the lockers of MERALCO linesmen. Respondent reported the matter to the Philippine National Police. In July 2008, petitioner Alexander Deyto directed respondent's transfer to MERALCO's Alabang Sector due to reports of accusations and threats against her which could potentially compromise her safety. Respondent appealed the transfer, claiming that it was punitive in nature and denied her due process. She expressed concerns about the alleged threats to her security and requested for the implementation of the transfer to be deferred. When no response was received, respondent filed a petition for the issuance of a writ of habeas data against petitioners before the Regional Trial Court (RTC) of Bulacan. Respondent alleged that petitioners' failure to provide her with details or information about the alleged threats violated her right to privacy in life, liberty, and security. She prayed for the disclosure of the information about the report, the measures taken to ensure its confidentiality, and the accuracy of the information. Respondent also sought a temporary restraining order (TRO) to prevent her transfer. The RTC directed petitioners to file their written return and granted respondent's application for a TRO.

ISSUES:

  1. Whether the respondent's plea for the writ of habeas data is justified under the given circumstances.

  2. Whether the RTC has jurisdiction over the case, given that it involves issues related to the terms and conditions of employment.

RULING:

  1. The plea for the writ of habeas data is not justified: The Court held that the respondent's plea does not fall within the province of a writ of habeas data. The writ of habeas data is designed to protect the right to privacy in life, liberty, or security against unlawful acts or omissions by entities engaged in gathering, collecting, or storing data. In this case, there was no showing that petitioners committed any unjustifiable or unlawful violation of respondent's right to privacy in relation to life, liberty, or security.

  2. RTC's lack of jurisdiction: The Court ruled that concerns respecting the terms and conditions of one's employment, including disputes about the transfer of employees, fall under the jurisdiction of the National Labor Relations Commission (NLRC) and the Labor Arbiters. Therefore, the RTC lacked jurisdiction over the case.

PRINCIPLES:

  • Writ of Habeas Data: Designed to protect one's right to privacy in life, liberty, and security against unlawful acts by those engaged in gathering, collecting, or storing personal data.

  • Labor Jurisdiction: Employment disputes relating to terms and conditions, including employee transfers, fall within the jurisdiction of the NLRC and Labor Arbiters, not regular courts.

  • Non-Applicability for Commercial Concerns: Writs of habeas data will not issue to protect purely property or commercial concerns.

  • Unjustifiable Violation of Privacy: A claim under the writ of habeas data requires a demonstration of an unlawful violation of the right to privacy linked to life, liberty, or security.