Case Digest (G.R. No. 171212) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Indophil Textile Mills, Inc. v. Engr. Salvador Adviento, petitioner Indophil Textile Mills, Inc., a domestic corporation manufacturing weaving thread, employed respondent Engr. Salvador Adviento on August 21, 1990, as Civil Engineer to maintain its facilities in Lambakin, Marilao, Bulacan. On August 7, 2002, Adviento consulted a physician for recurring weakness and dizziness and was diagnosed with Chronic Poly Sinusitis and severe Allergic Rhinitis, for which he was advised to avoid house dust mites and textile dust. Distressed by continued exposure in the hot, foul-smelling dye house without adequate dust-control measures, he first filed a complaint for illegal dismissal and related reliefs before the NLRC, which remained pending. Thereafter, Adviento filed a separate quasi-delict complaint in the Regional Trial Court (RTC) of Aparri, Cagayan, alleging that petitioner’s gross negligence in maintaining a safe, healthy, and workable environment caused his occupational disease Case Digest (G.R. No. 171212) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Indophil Textile Mills, Inc. – a domestic corporation manufacturing thread for weaving.
- Engr. Salvador Adviento – hired on August 21, 1990 as Civil Engineer to maintain Indophil’s facilities in Lambakin, Marilao, Bulacan.
- Factual Background
- On August 7, 2002, Adviento experienced recurring weakness and dizziness; diagnosed with chronic poly sinusitis and severe, persistent allergic rhinitis; advised to avoid house dust mite and textile dust.
- Adviento filed a complaint with the NLRC (NLRC Case No. RAB-III-05-5834-03) for illegal dismissal, backwages, separation pay, actual and moral damages, attorney’s fees.
- He filed a separate complaint with the RTC of Aparri, Cagayan, alleging occupational disease due to gross negligence in providing a safe, healthy, workable environment (dusty dye house, poor ventilation, chemical fumes) and sought moral (₱5,000,000), exemplary (₱2,000,000) and compensatory (₱7,003,008) damages.
- Petitioner moved to dismiss before the RTC on grounds of lack of jurisdiction (Article 217(a)(4), Labor Code) and lis pendens; RTC denied the motion (Decision December 29, 2003; denied reconsideration February 9, 2004).
- Petitioner sought certiorari from the Court of Appeals (CA); CA dismissed the petition for lack of merit (Decision May 30, 2005; Resolution January 10, 2006).
- Petitioner filed a Rule 45 petition before the Supreme Court, contending the RTC lacked jurisdiction over the quasi-delict claim.
Issues:
- Primary Issue
- Whether the RTC has jurisdiction over Adviento’s complaint for moral, exemplary and compensatory damages grounded on petitioner’s alleged gross negligence in failing to provide a safe and healthy work environment.
- Whether exclusive original jurisdiction lies with the Labor Arbiter and the NLRC under Article 217(a)(4) of the Labor Code, as petitioner claims.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)