Almirante: Jurisdiction over quasi-delict

Labor Case Digest

ON JAN. 1, 1998, Magsaysay Maritime Corp. (Magsaysay), the manning agent of respondent Mitsui O.S.K. Lines, hired 16 Filipino sailors in various capacities ranging from captain to ordinary sailor. They were assigned to M/V Sea Prospect with a regular route between Japan and Indonesia.

On Aug. 26, 1998, while it was heading to Japan, M/V Sea Prospect encountered inclement weather and sank drowning 10 crew members. Eleven others were saved. Petitioners who are heirs and beneficiaries of the missing seafarers filed a complaint for damages and attorney’s fees against respondent with the Labor Arbiter (LA).

Does the Labor Arbiter have jurisdiction over the case?

Ruling: No.

In deciding whether a case arises out of employer-employee relations, the Court formulated the “reasonable causal connection rule,” wherein if there is a reasonable connection between the claim asserted and the employer-employee relations, then the case is within the jurisdiction of the labor courts.

In this case, petitioners’ claim for damages is grounded on respondents’ gross negligence which caused the sinking of the vessel and the untimely demise of their loved ones. Based on this, the subject matter of the complaint is one of claim for damages arising from quasi-delict, which is within the ambit of the regular court’s jurisdiction.

According to Article 2176 of the New Civil Code, “Whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called quasi-delict.” Thus, to sustain a claim liability under quasi-delict, the following requisites must concur: (a) damages suffered by the plaintiff; (b) fault or negligence of the defendant, or some other person for whose acts he must respond; and (c) the connection of cause and effect between the fault or negligence of the defendant and the damages incurred by the plaintiff.

Here, petitioners argue that respondents are duty bound to exercise due diligence required by law in order to ensure the safety of the crew and all the passengers therein. It was further averred that the negligence on the part of the respondents is quite apparent when they allowed the vessel to load and transport wet cargo. For failure therefore to exercise extraordinary diligence required of them, the respondents must be held liable for damages to the surviving heirs of the deceased crew members. Notwithstanding the contractual relation between the parties, the act of respondents is a quasi-delict and not a mere breach of contract.

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 or expertise ordinarily ascribed to the LA and the National Labor Relations Commission.

Therefore, the LA has no jurisdiction over the case in the first place; it should have been filed to the proper trial court. (Spouses Hipolito Dalen Sr. and Fe G. Dalen, et al. vs. Mitsui O.S.K. Lines, et al., G.R. 194403, July 24, 2019).


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