MANILA ELECTRIC VS.

LIM 632 SCRA 195 (2010)

Facts:
A letter was sent to the Meralco admin department in bulacan denouncing Lim, an
administrative clerk. She was ordered to be transferred to Alabang due to concerns over her
safety. She complained under the premise that the transfer was a denial of her due process. She
wrote a letter stating that:
“It appears that the veracity of these accusations and threats to be [sic] highly suspicious,
doubtful or are just mere jokes if they existed at all.” She added, “instead of the management
supposedly extending favor to me, the net result and effect of management action would be a
punitive one.” She asked for deferment thereafter. Since the company didn’t respond, she filed
for a writ of habeas data in the Bulacan RTC due to meralco’s omission of provding her with
details about the report of the letter. To her, this constituted a violation of her liberty and
security. She asked for disclosure of the data and measures for keeping the confidentiality of
the data.
Meralco filed a reply saying that the jurisdiction was with the NLRC and that the petition wasn’t
in order.
Trial court ruled in her favor.
In the SC, Meralco petitioned that Habeas Data applies to entities engaged in the gathering,
collecting or storing of data or information regarding an aggrieved party’s person, family or
home

Issue: Is Habeas Data the right remedy for Lim?

Held: No, petition dismissed

Ratio:
“Section 1. Habeas Data. – The writ of habeas data is a remedy available to any person whose
right to privacy in life, liberty or security is violated or threatened by an unlawful act or omission
of a public official or employee or of a private individual or entity engaged in the gathering,
collecting or storing of data or information regarding the person, family, home and
correspondence of the aggrieved party”
It’s a forum for enforcing one’s right to the truth. Like amparo, habeas data was a response to
killings and enforced disappearances.
Castillo v Cruz- and habeas data will NOT issue to protect purely property or commercial
concerns nor when the grounds invoked in support of the petitions therefor are vague or
doubtful.
Employment is a property right in the due process clause. Lim was concerned with her
employment, one that can be solved in the NLRC.
There was no violation of respondent’s right to privacy. Respondent even said that the letters
were mere jokes and even conceded the fact that the issue was labor related due to references
to “real intent of management”.