Case Digest (G.R. No. 184769)
Facts:
In Manila Electric Company, Alexander S. Deyto and Ruben A. Sapitula v. Rosario Gopez Lim (G.R. No. 184769, October 5, 2010), respondent Rosario Gopez Lim, an administrative clerk at MERALCO’s Plaridel, Bulacan Sector, discovered on June 4, 2008 an anonymous letter posted at her office door and inserted in linesmen’s lockers accusing her of disloyalty and calling for her removal. The next day she reported the matter to the Plaridel PNP Station. On July 4, 2008, Alexander S. Deyto, Head of Human Resource Staffing, issued a “Management Initiated Transfer” memorandum directing her reassignment to MERALCO’s Alabang Sector effective July 18, 2008, citing threats to her safety from unknown individuals. By letter dated July 10, 2008 to Vice-President Ruben A. Sapitula, respondent appealed the transfer as punitive, citing due process concerns, onerous travel, collective bargaining provisions, and her right to know the nature and source of the alleged threats. Receiving no reply, she filCase Digest (G.R. No. 184769)
Facts:
- Background of the Parties and Incident
- Rosario G. Lim (“respondent”), an administrative clerk of MERALCO Plaridel, Bulacan Sector, was denounced by an anonymous letter posted on June 4, 2008, accusing her of disloyalty and demanding her departure.
- Copies of the same letter were inserted in the lockers of MERALCO linesmen; respondent reported the matter to the PNP the following day.
- Transfer Order and Respondent’s Reaction
- By Memorandum dated July 4, 2008, MERALCO’s Head of HR Staffing ordered respondent’s transfer to the Alabang Sector effective July 18, 2008, citing “reports” of accusations and threats against her that might endanger her security.
- On July 10, 2008, respondent appealed the transfer to MERALCO’s VP for HR Administration, complained of denial of due process, excessive travel burden, alleged CBA violation, and requested disclosure of the nature and source of the reported threats as well as deferment of the transfer.
- Proceedings Below
- When no reply was received, respondent filed in the RTC of Bulacan (SP Proc. No. 213-M-2008) a petition for writ of habeas data, seeking full disclosure of data on the alleged threats, measures for confidentiality, and accuracy of such data; she also sought a TRO to enjoin her transfer.
- The RTC issued an order to file a verified return, granted the TRO, and later issued a writ of preliminary injunction preventing MERALCO from effecting the transfer until disclosure of the requested information. MERALCO moved to dismiss, arguing lack of jurisdiction and misuse of habeas data.
Issues:
- Jurisdiction
- Whether the RTC had jurisdiction to entertain respondent’s petition and issue injunctive relief restraining MERALCO’s managerial prerogative to transfer an employee.
- Whether the dispute is essentially a labor matter belonging to the NLRC under Article 217 of the Labor Code.
- Appropriateness of Habeas Data
- Whether the writ of habeas data is the proper remedy to compel disclosure of alleged internal reports on threats to respondent’s safety.
- Whether respondent’s claim of violated “privacy in life, liberty or security” falls within the scope of the Rule on the Writ of Habeas Data.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)