“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 54

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