Reasonable Causal Connection Rule;
Reasonable Causal Connection Rule (RCC) + Sole Reference to Labor Law Rule (SRLL) = LABOR JURISDICTION (LJ)
While we
have upheld the present trend to refer worker-employer controversies to labor
courts in light of the aforequoted provision, [Art. 224 (formerly Art. 217 of
Labor Code)] we have also recognized that not all claims involving employees
can be resolved solely by our labor courts, specifically when the law provides
otherwise. For this reason, we have 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. Such distinction is apt since it
cannot be presumed that money claims of workers which do not arise out of or in
connection with their employer-employee relationship, and which would therefore
fall within the general jurisdiction of the regular courts of justice, were
intended by the legislative authority to be taken away from the jurisdiction of
the courts and lodged with Labor Arbiters on an exclusive basis. (INDOPHILTEXTILE MILLS, INC., v. ADVIENTO, 2014)
Not The jurisdiction
of LJ:
1. when the claim for damages is grounded on the "wanton failure and refusal" without just cause of an employee to report for duty despite repeated notices served upon him of the disapproval of his application for leave of absence, the same falls within the purview of Civil Law, (INDOPHIL TEXTILE MILLS, INC., v.ADVIENTO, 2014, citing Portillo v. Rudolf Lietz, Inc.)
2. The Labor Arbiter has no jurisdiction over tort cases; (Spouses Dalen vs. Mitsui O.S.K. Lines Diamond Camella, 2019)
3. 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 NLRC. (Spouses Dalen vs. Mitsui O.S.K. Lines Diamond Camella, 2019, S.A. citing INDOPHIL TEXTILE MILLS, INC., v. ADVIENTO)