Case Summary (G.R. No. 184769)
Respondent’s Appeal and Request for Disclosure
By letter dated July 10, 2008 to petitioner Sapitula, respondent appealed the transfer, claimed it was punitive and violative of due process and the Collective Bargaining Agreement, and requested a dialogue to voice concerns. She specifically requested that management disclose the nature and details of the alleged accusations and threats so she could assess their credibility; she also asked for deferment of the transfer pending resolution of these issues.
Habeas Data Petition and Early RTC Actions
Respondent filed a petition for the issuance of a writ of habeas data before the Regional Trial Court (Bulacan) (SP. Proc. No. 213-M-2008), alleging that petitioners’ continued refusal to disclose details of the purported report violated her right to privacy in life, liberty and security. She sought a writ commanding disclosure of the data/information concerning the alleged threats (including nature, purpose, confidentiality measures, and accuracy) and requested a Temporary Restraining Order (TRO) enjoining the transfer. The RTC ordered petitioners to file a verified written return (Aug 29, 2008) and granted a TRO (Sept 5, 2008).
Trial Court’s Decision Granting Habeas Data Relief
On September 22, 2008, the RTC granted respondent’s prayers and issued a writ of preliminary injunction directing petitioners to desist from effecting the transfer until the required disclosures were made. The trial court held that the writ of habeas data is available not only to victims of extrajudicial killings and political activists but also to ordinary citizens whose life and security are jeopardized by refusal to disclose information.
Petitioners’ Supreme Court Contentions
Petitioners sought review, arguing primarily that (1) the RTC lacked jurisdiction because the matter was essentially a labor dispute concerning management prerogative to transfer an employee and thus within the exclusive competence of the NLRC and labor arbiters under Article 217 of the Labor Code; and (2) the writ of habeas data was inapplicable because the Rule limits relief to actions against public officials/employees or private entities engaged in gathering/collecting/storing data about the person, family, home, or correspondence of the aggrieved, which MERALCO (or its officers) were not shown to be doing. Petitioners also invoked OCA Circular No. 79-2003, cautioning judges against issuing TROs in labor-related cases.
Legal Standard — Purpose and Scope of the Writ of Habeas Data
Section 1 of the Rule on the Writ of Habeas Data defines the remedy as available to any person whose right to privacy in life, liberty or security is violated or threatened by an unlawful act or omission of a public official or employee, or of a private individual or entity engaged in gathering, collecting or storing data or information regarding the person, family, home and correspondence of the aggrieved party. The writ’s general design is to protect image, privacy, honor, and informational privacy and to provide a forum to enforce the right to truth and informational privacy, thereby safeguarding constitutional guarantees of life, liberty and security. The writ, conceived alongside the writ of amparo, was intended as an extraordinary remedy in response to enforced disappearances and killings and is not a substitute for ordinary remedies where those exist.
Court’s Analysis — Labor Character of the Dispute and Limitations on Habeas Data Relief
The Supreme Court determined that respondent’s primary contention concerns the terms and conditions of employment — specifically, the propriety and motive of management’s decision to transfer her — which is a property-related matter (employment as a property inte
...continue readingCase Syllabus (G.R. No. 184769)
Case Citation and Decision
- Reported at 646 Phil. 497, En Banc, G.R. No. 184769, decided October 05, 2010.
- Decision authored by Justice Carpio Morales; Justices Corona, Carpio, Velasco, Jr., Nachura, Leonardo-De Castro, Peralta, Bersamin, Del Castillo, Abad, Villarama, Jr., Perez, Mendoza, and Sereno concurred; Justice Brion on official leave.
- The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the September 22, 2008 Decision of the Regional Trial Court (RTC), Branch 7, Bulacan in SP. Proc. No. 213-M-2008, and DISMISSED the special proceeding.
Parties
- Petitioners: Manila Electric Company (MERALCO), Alexander S. Deyto (Head of MERALCO's Human Resource Staffing), and Ruben A. Sapitula (Vice-President and Head of MERALCO's Human Resource Administration).
- Respondent: Rosario Gopez Lim (also known as Cherry Lim), an administrative clerk at MERALCO.
Factual Background
- On June 4, 2008, an anonymous letter denouncing respondent was posted at the door of the Metering Office of MERALCO's Administration building in Plaridel, Bulacan Sector, where respondent was assigned.
- The anonymous letter addressed to "Cherry Lim" contained Filipino-language denunciatory text accusing respondent of having consumed MERALCO's favors and seeking to harm the company by working with "crooked" government elements, and told her to leave.
- Copies of the anonymous letter were inserted in the lockers of MERALCO linesmen.
- Respondent reported the matter to the Plaridel Station of the Philippine National Police on June 5, 2008.
- By Memorandum dated July 4, 2008 titled "Management Initiated Transfer," petitioner Alexander Deyto directed the transfer of respondent to MERALCO's Alabang Sector in Muntinlupa as "A/F OTMS Clerk," effective July 18, 2008, citing receipt of "reports that there were accusations and threats directed against [her] from unknown individuals and which could possibly compromise [her] safety and security."
- Respondent, by letter dated July 10, 2008 addressed to petitioner Ruben Sapitula, appealed the transfer, requested a dialogue, and characterized the transfer as "punitive" and a denial of due process.
- In her July 10, 2008 letter, respondent explained the hardship of travel from Pampanga to Alabang and invoked violations of job security provisions in the Collective Bargaining Agreement (CBA).
- Respondent expressly stated that she believed the alleged accusations and threats were "highly suspicious, doubtful or are just mere jokes if they existed at all," and that the transfer might betray management's "real intent" and could be punitive.
Procedural History in Lower Court
- Respondent sought deferment of the transfer pending resolution of her concerns; no response was received from petitioners.
- Respondent filed a petition for issuance of a writ of habeas data against petitioners before the RTC of Bulacan, docketed SP. Proc. No. 213-M-2008.
- Respondent alleged petitioners' refusal to provide details concerning the alleged report of threats violated her right to privacy in life, liberty, and security, and sought a writ commanding disclosure of data and related relief, including:
- Full disclosure of the data or information regarding the reported threats, nature and purpose of data collection;
- Measures taken to ensure confidentiality of such data; and
- Currency and accuracy of such data.
- Respondent also prayed for a Temporary Restraining Order (TRO) enjoining petitioners from effecting her transfer to Alabang.
- On August 29, 2008, RTC Branch 7 directed petitioners to file a verified written return.
- On September 5, 2008, the trial court granted respondent's application for a TRO.
- Petitioners moved to dismiss and recall the TRO, arguing the writ of habeas data was not the proper remedy and that the RTC lacked jurisdiction because the matter was a labor dispute under the NLRC.
- On September 22, 2008, the trial court granted respondent's prayers, issued a writ of preliminary injunction directing petitioners to desist from implementing the transfer until disclosures were made, and justified the availability of habeas data to ordinary citizens whose life and security are jeopardized by refusal to disclose information.
Reliefs Sought by Respondent
- Issuance of a writ of habeas data requiring petitioners to disclose information and data concerning alleged threats.
- Disclosure of the nature, purpose, confidentiality measures, and accuracy of data.
- A TRO and injunctive relief to prevent immediate implementation of the transfer.
Petitioners' Claims and Arguments
- Petitioners contended the RTC lacked jurisdiction and the case was essentially a labor dispute falling under the exclusive competence of the National Labor Relations Commission (NLRC) and Labor Arbiters under Article 217 of the Labor Code.
- Petitioners asserted the matter was an employer's management prerogative to transf