G.R. No. 171212
August 4, 2014
Facts
Petitioner is a domestic corporation engaged in the business of manufacturing thread for weaving. Respondent is an engineer employed by the petitioner.
After 12 years of working in petitioner’s company, respondent was diagnosed with Chronic Poly Sinusitis and with moderate, severe, and persistent Allergic Rhinitis. Thereafter, respondent filed a Complaint with the Regional Trial Court, alleging that he contracted such occupational disease by reason of the gross negligence of petitioner to provide him with a safe, healthy and workable environment.
In his complaint, respondent alleged that he conducts regular maintenance check on petitioner’s facilities including its dye house area, which is very hot and emits foul chemical odor with no adequate safety measures introduced by petitioner. The respondent’s recommendation to the management to place roof insulation to minimize, if not, eradicate the health hazards attendant in the work place and to relocate the engineering office because of its dent location fell into deaf ears.
On the contrary, petitioner filed a motion to dismiss on the ground that the RTC has no jurisdiction over the subject matter of the complaint because the same falls under the original and exclusive jurisdiction of the Labor Arbiter (LA) under Article 217 (a) (4) of the Labor Code. The RTC dismissed the petitioner’s motion to dismiss. Such dismissal was affirmed by the Court of Appeals. Hence, this petition.
Petitioner averred petitioner argues that respondent’s claim for damages is anchored on the alleged gross negligence of petitioner as an employer to provide its employees, including herein respondent, with a safe, healthy and workable environment; hence, it arose from an employer-employee relationship. The fact of respondent’s employment with petitioner as a civil engineer is a necessary element of his cause of action because without the same, respondent cannot claim to have a right to a safe, healthy and workable environment. Hence, the Labor Arbiter not the RTC has jurisdiction.
Issue
Who between the RTC and the LA has jurisdiction over the subject matter of the complaint?
Held
The RTC has jurisdiction.
Not all claims involving employees can be resolved solely by our labor courts, specifically when the law provides otherwise. Claims for damages under Article 217 (a) (4) of the Labor Code, to be cognizable by the LA, must have a reasonable causal connection with any of the claims provided for in that article. Only if there is such a connection with the other claims can a claim for damages be considered as arising from employer-employee relations. Otherwise, the regular courts has jurisdiction.
In this case, there is no reasonable causal connection. Respondent’s claim for damages is specifically grounded on petitioner’s gross negligence to provide a safe, healthy and workable environment for its employees — a case of quasi-delict. In addition, respondent alleged that despite his earnest efforts to suggest to management to place roof insulation to minimize, if not, eradicate the health hazards attendant in the workplace, the same was not heeded. A perusal of the complaint would reveal that the subject matter is one of claim for damages arising from quasi-delict, which is within the ambit of the regular court’s jurisdiction.