Case Summary (G.R. No. 171212)
Employment, Diagnosis, and Medical Advice
In August 2002, respondent experienced recurring weakness and dizziness. He was diagnosed with chronic poly-sinusitis and severe allergic rhinitis traced to textile dust exposure. His physician advised complete avoidance of house dust mite and textile dust.
NLRC Complaint for Illegal Dismissal
Respondent filed a complaint with the NLRC, San Fernando, Pampanga (NLRC Case No. RAB-III-05-5834-03), alleging illegal dismissal and seeking backwages, separation pay, actual damages, and attorney’s fees. That case remained pending.
Civil Action for Occupational Disease
Subsequently, respondent brought a separate complaint before the RTC of Aparri, Cagayan, asserting that petitioner’s gross negligence in maintaining a dust-laden, chemically hazardous workplace caused his irreversible occupational disease. He prayed for moral, exemplary, and compensatory damages.
RTC’s Denial of Motion to Dismiss
Petitioner moved to dismiss for lack of jurisdiction—contending exclusive labor arbiter jurisdiction under Article 217(a)(4) and lis pendens. On December 29, 2003, the RTC denied the motion, holding the claim to be quasi-delictual negligence, outside the Labor Code’s exclusive ambit, and noting the NLRC case involved illegal dismissal, not workplace negligence.
CA’s Dismissal of Petition for Certiorari
The Court of Appeals, in a May 30, 2005 decision, and January 10, 2006 resolution, dismissed petitioner’s certiorari petition for lack of merit, upholding the RTC’s exercise of jurisdiction over the tort-based claim.
Jurisdictional Issue – Labor vs. Civil Courts
The Supreme Court framed the sole issue as whether the RTC properly assumed jurisdiction over respondent’s negligence-based damage claim, given the overlapping employer-employee relationship and the Labor Code’s coverage of certain damage claims.
Reasonable Causal Connection Rule
Jurisdiction depends on whether a claim for damages bears a reasonable causal connection to specific labor claims under Article 217(a)(4). If connected, the Labor Arbiter has exclusive original jurisdiction; if not, regular courts preside.
Quasi-Delict Character of the Claim
Respondent’s complaint details petitioner’s omissions—excessive textile dust, inadequate suction systems, use of air compressors, lack of respiratory medical support, and chemical hazards—as independent acts of negligence causing his occupational disease. These elements constitute a quasi-delict under Civil Code Article 2176.
Civil Code Article 2176 Criteria
Under Article 2176, liability arises when fault or negligence causes damage absent a pre-existing contractual relation. The requisites—damage, defendant’s negligence, and a direct causal
...continue readingCase Syllabus (G.R. No. 171212)
Parties and Nature of the Case
- Petitioner: Indophil Textile Mills, Inc., a domestic corporation engaged in manufacturing thread for weaving.
- Respondent: Engr. Salvador Adviento, formerly employed by petitioner as a Civil Engineer.
- Subject Matter: Jurisdictional dispute over respondent’s complaint for damages based on alleged gross negligence in maintaining a safe and healthy workplace, raised as a quasi-delict claim in the RTC versus exclusive original jurisdiction claimed by labor tribunals under the Labor Code.
Facts of Employment and Medical Condition
- On August 21, 1990, respondent was hired to maintain petitioner’s facilities in Lambakin, Marilao, Bulacan.
- In early August 2002, respondent experienced recurring weakness and dizziness; diagnosed with chronic poly‐sinusitis and moderate to severe allergic rhinitis.
- His physician advised total avoidance of house dust mite and textile dust to prevent further health deterioration.
Workplace Environment and Safety Complaints
- Respondent’s duties included regular maintenance checks in the dye house area, characterized by high heat, foul chemical odor, airborne textile dust and inadequate safety measures.
- He observed that air washer dampers and roof exhaust vents discharged dust into the open air without proper control or filtration.
- Respondent twice recommended to management:
• Installation of roof insulation to reduce dust exposure;
• Relocation of the engineering office away from a “dust-prone” section of the plant. - Both recommendations were rejected by management on cost grounds, and subsequent filter installations aggravated dust infiltration.
- Other employees similarly complained of persistent health hazards, yet petitioner remained indifferent to their plight.
Consequences and Damages Claimed
- Respondent alleges permanent, incurable work-related disease and inability to secure alternative employment due to his condition.
- He prays for moral damages of ₱5,000,000.00, exemplary damages of ₱2,000,000.00, and compensatory damages of ₱7,003,008.00, citing intense moral suffering, mental anguish, anxiety, and wounded feelings.
- Declared a pauper litigant, respondent was exempt from filing fees.