View full case

INDOPHIL TEXTILE MILLS v. ENGR. SALVADOR ADVIENTO

FACTS:

Petitioner Indophil Textile Mills, Inc. is a domestic corporation involved in the manufacturing of weaving thread. On August 21, 1990, it employed respondent, Engr. Salvador Adviento, as a Civil Engineer responsible for maintaining its facilities located in Lambakin, Marilao, Bulacan. In early August 2002, respondent sought medical consultation due to recurring weakness and dizziness, and was subsequently diagnosed with Chronic Poly Sinusitis and Allergic Rhinitis, conditions which necessitated the complete avoidance of house dust and textile dust as advised by his physician. Consequently, respondent filed a complaint against the petitioner with the National Labor Relations Commission (NLRC) in San Fernando, Pampanga, for illegal dismissal, backwages, separation pay, actual damages, and attorney's fees, which was still unresolved at the time of filing the present petition. Respondent also instituted another complaint with the Regional Trial Court (RTC) of Aparri, Cagayan, alleging that the occupational diseases he contracted were due to the gross negligence of petitioner in providing a safe, healthy, and workable environment. The complaint detailed that part of respondent's job involved regular maintenance checks in areas like the dye house, which was identified as having hazardous conditions such as excessive heat, foul chemical odors, and inadequate safety measures. Despite suggestions for improvements like roof insulation and relocating the engineering office, management rejected these proposals due to cost concerns. Consequently, respondent along with other workers, experienced persistent health problems which were reportedly ignored by the petitioner leading to respondent’s claims for moral, exemplary, and compensatory damages totaling approximately 14 million pesos. Additionally, respondent filed as a pauper litigant, which exempted him from paying any filing fees. In response, petitioner moved to dismiss the RTC complaint, asserting that the subject matter was under the jurisdiction of the Labor Arbiter and that there was a concurrent case pending with the NLRC. However, RTC denied the motion, asserting jurisdiction based on the nature of the complaint being a case of quasi-delict. After petitioner's motion for reconsideration was likewise dismissed, they sought certiorari with the Court of Appeals (CA), which upheld the RTC’s jurisdiction. The CA’s decision and subsequent denial of petitioner’s motion for reconsideration led to the filing of the instant petition with the Supreme Court.

ISSUES:

  1. Does the Regional Trial Court (RTC) have jurisdiction over the complaint for damages anchored on the gross negligence of the employer in providing a safe and healthy working environment?

RULING:

  1. Yes, the RTC has jurisdiction over the complaint. The Supreme Court ruled that while the maintenance of a safe and healthy workplace typically falls under labor cases, the complaint in this case is grounded on quasi-delict due to the employer's gross negligence. The jurisdiction over such claims, especially where there is no reasonable causal connection to labor claims, rests with the regular courts.

PRINCIPLES:

  1. Reasonable Causal Connection Rule If there is a reasonable causal connection between the claim asserted and the employer-employee relationship, the case falls within the jurisdiction of labor courts. Otherwise, regular courts have jurisdiction.

  2. Quasi-Delict Under Article 2176 of the Civil Code, a quasi-delict involves damage caused by fault or negligence, with no pre-existing contractual relation between the parties.

  3. Jurisdiction Determination Jurisdiction over the subject matter is determined based on the allegations in the complaint and cannot be influenced by defenses raised by the respondent.

  4. Distinction Between Labor and Regular Courts Not all disputes between employers and employees fall within the jurisdiction of labor tribunals, especially if claims arise after the cessation of the employment relationship or are heavily grounded in civil law rather than labor law.

  5. Claims for Damages under Article 217(a)(4) of the Labor Code To be cognizable by the Labor Arbiter, claims for damages must have a reasonable causal connection with the claims provided in the Labor Code regarding unfair labor practices or termination disputes.

By applying these principles, the Supreme Court affirms that the jurisdiction over the complaint lies with the regular courts due to the nature of the allegations as quasi-delict.