“Similarly, Section 10 of Republic Act No. 8042 or the Migrant
Workers and Overseas Filipinos Act of 1995 provides:
‘Sec. 10. MONEY CLAIMS. - Notwithstanding any
provision of law to the contrary, the Labor Arbiters of the
National Labor Relations Commission (NLRC) shall have the
original and exclusive jurisdiction to hear and decide, within
ninety (90) calendar days after filing of the complaint, the
claims arising out of an employer-employee relationship or by
virtue of any law or contract involving Filipino workers for
overseas deployment including claims for actual, moral,
exemplary and other forms of damages’
“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 employeremployee 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 preexisting 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 extra ordinary 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
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