G.R. No. 202481 , September 8, 2020.
ALBERT B. DEL ROSARIO, ET AL., PETITIONERS, V. ABS-CBN BROADCASTING CORPORATION, RESPONDENT. (Consolidated with G.R. Nos. 202495 & 202497, 210165, 219125, 222057, 224879, 225101, and 225874)

FACTS

These consolidated Petitions for Review on Certiorari under Rule 45 originated from complaints for regularization and illegal dismissal filed by various workers against ABS-CBN Broadcasting Corporation. Initially, 135 workers (later reduced to 95) filed complaints for regularization. These led to two consolidated cases in the Court of Appeals with conflicting outcomes: one set of complainants was declared regular employees, while another was declared independent contractors. Subsequently, 20 of these workers filed separate complaints for illegal dismissal. The workers held various positions in television production, such as camera operators, light technicians, audio technicians, and drivers. ABS-CBN defended itself by claiming it is principally engaged in broadcasting, not production; that the workers are independent contractors or “talents” hired for specific projects based on unique skills; that they are part of an “Internal Job Market System” database and are not exclusively bound to ABS-CBN; and that they work independently without supervision.

ISSUE

The primary legal issue involves the determination of whether the workers are regular employees of ABS-CBN or independent contractors, which directly impacts the resolution of their claims for regularization and illegal dismissal.

RULING

The Concurring Opinion of Justice Leonen concurs with the ponencia’s result but emphasizes the proper standard of review. In a Rule 45 petition reviewing a Court of Appeals decision on a labor case, the Supreme Court’s review is limited to determining the correctness of the Court of Appeals’ findings on the existence or lack of grave abuse of discretion by the National Labor Relations Commission. The opinion references Montoya v. Transmed Manila Corporation to underscore that the review under Rule 45 is confined to questions of law, in contrast to the review for jurisdictional error under Rule 65. The opinion does not dispute the factual findings or the ultimate conclusion on the workers’ status but stresses the procedural boundary of the Court’s review power in these consolidated cases.