Does the exclusiveness of the Workers' Compensation Act preclude a wrongful termination claim?

Our decision should not be construed to hold that the exclusivity provisions of the Workers' Compensation Act can never preclude a wrongful termination claim because the injury sought to be redressed by such a claim is loss of employment, not a "personal injury" or death. "[When] the essence of the wrong is personal physical injury or death, the action is barred by the exclusiveness clause no matter what its name or technical form ..." (Cole v. Fair Oaks Fire Protection Dist., supra, 43 Cal.3d 148, 160, 233 Cal.Rptr. 308, 729 P.2d 743, emphasis added.) The crucial question is what is the nature of the actual underlying injury for which the former employee is trying to recover, not what cause of action is alleged.