INDOPHIL TEXTILE MILLS, INC.,v. ENGR. SALVADOR ADVIENTO.

G.R. No. 171212, 20 August 2014, THIRD DIVISION, (Peralta, J.)

Regular courts have jurisdiction over the negligent act of an employerwho failed to provide
a safe and healthy working environment. The Court formulated the “reasonable causal connection
rule,” wherein if there is a reasonable causal connection between the claim asserted and the
employer-employee relations, then the case is within the jurisdiction of the labor courts; and in the
absence thereof, it is the regular courts that have jurisdiction.

Engr. Salvador Adviento was hired by Indophil Textile Mills, Inc.

(Indophil) to maintain its thread manufacturing business in Bulacan. Adviento
alleged that there were no adequate safety measures introduced by Indophil when he
conducted a maintenance check on the dye house area.The workplace is very hot
and emits foul chemical odor. According to Adviento, the air washer dampers and
all roof exhaust vests are blown into open air, carrying dust thereto. He
recommended to management to place roof insulation but such was turned down by
management due to high cost. Twelve years later, Adviento experienced weakness
and dizziness, and was thereafter diagnosed with Chronic Poly Sinusitis and Allergic
Rhinitis.

Adviento 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. Indophil argued 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.RTC
sustained its jurisdiction on the ground that the case is a quasi-delict, that Indophil's
failure to provide its employees with a safe, healthy and workable environment is an
act of negligence.

ISSUE:

Does RTC have jurisdiction over a negligent employerwhofailed to provide

a safe and healthy working environment?

RULING:

Yes, the jurisdiction rests on the regular courts.According to the Court, not
all claims involving employees can be resolved solely by labor courts, specifically
when the law provides otherwise.

The Court formulated the “reasonable causal connection rule,” wherein if

there is a reasonable causal connection between the claim asserted and the
employer-employee relations, then the case is within the jurisdiction of the labor
courts; and in the absence thereof, it is the regular courts that have jurisdiction.

UST Law Review, Vol. LIX, No. 1, May 2015

 In the case at bar, Adviento's claim for damages is specifically grounded on
Indophil's gross negligence to provide a safe, healthy and workable environment for
its employees –a case of quasi-delict. The Court ascertained this from reading the
complaint, which enumerated the acts and/or omissions of Indophil relative to the
conditions in the workplace.

It is a basic tenet that jurisdiction over the subject matter is determined

upon the allegations made in the complaint, irrespective of whether or not the
plaintiff is entitled to recover upon the claim asserted therein, which is a matter
resolved only after and as a result of a trial.Neither can jurisdiction of a court be
made to depend upon the defenses made by a defendant in his answer or motion to
dismiss. In this case, 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.

Adviento alleges that due to the continued and prolonged exposure to

textile dust seriously inimical to his health, he suffered work-contracted disease
which is now irreversible and incurable, and deprived him of job
opportunities.Clearly, injury and damages were allegedly suffered by respondent, an
element of quasi-delict.

It also bears stressing that respondent is not praying for any relief under the
Labor Code of the Philippines. He neither claims for reinstatement nor backwages
or separation pay resulting from an illegal termination. The cause of action herein
pertains to the consequence of petitioner’s omission which led to a work-related
disease suffered by respondent, causing harm or damage to his person. Such cause
of action is within the realm of Civil Law, and jurisdiction over the controversy
belongs to the regular courts.

Where the resolution of the dispute requires expertise, not in labor

management relations nor in wage structures and other terms and conditions of
employment, but rather in the application of the general civil law, such claim falls
outside the area of competence of expertise ordinarily ascribed to the LA and the
NLRC.The RTC has jurisdiction over the subject matter of respondent’s complaint
praying for moral damages, exemplary damages, compensatory damages, anchored
on petitioner’s alleged gross negligence in failing to provide a safe and healthy
working environment for respondent.

UST Law Review, Vol. LIX, No. 1, May 2015