G.R. No. 203876 , March 29, 2022
ABS-CBN CORPORATION, PETITIONER, VS. CLARA L. MAGNO, RESPONDENT.

FACTS

Respondent Clara L. Magno was employed by ABS-CBN Corporation since 1992, serving as a Production Assistant and later as a Video Tape Recorder (VTR) Playback Operator. In January 2002, she was placed under ABS-CBN’s Internal Job Market (IJM) system, a database of accredited technical/creative manpower hired as “talents,” without her consent. Magno worked on the program “Wowowee.” After its host, Willie Revillame, left ABS-CBN, the network launched “Pilipinas Win na Win!” (PWNW) on July 31, 2010, and Magno was assigned to it. ABS-CBN management allegedly became angered upon learning Magno attended a dinner hosted by Revillame. Magno claimed her superiors forced her to resign, compelling her to file a Resignation Letter dated August 16, 2010, addressed to the Executive Producer of PWNW, stating her intention to leave her position as VTR Playback Operator of the show. She alleged constructive dismissal afterwards when ABS-CBN stopped giving her work assignments. She subsequently worked for Revillame’s new show on another network. Magno filed a complaint for illegal dismissal, regularization, and monetary claims. The Labor Arbiter dismissed the complaint, ruling no employer-employee relationship existed as Magno was an independent contractor under the IJM system. The National Labor Relations Commission affirmed the dismissal. The Court of Appeals reversed, finding Magno was a regular employee who was constructively dismissed.

ISSUE

Whether an employer-employee relationship existed between ABS-CBN and Clara Magno, and if so, whether she was illegally dismissed.

RULING

Yes, an employer-employee relationship existed, and Magno was illegally dismissed. The Supreme Court affirmed the Court of Appeals decision. The four-fold test for employment was satisfied: ABS-CBN hired Magno; she received compensation from the company; it exercised control over her work through its supervisors and the assignment of specific programs and schedules; and it had the power to dismiss her, as evidenced by the circumstances leading to her resignation. Her long period of engagement (since 1992) performing work necessary and desirable to ABS-CBN’s broadcasting business made her a regular employee. The IJM system did not negate this relationship. Her resignation letter, stating she was leaving her position “of the show,” indicated an intent to resign only from PWNW, not from ABS-CBN entirely. ABS-CBN’s subsequent act of denying her work assignments constituted constructive dismissal, as it was an involuntary resignation due to unsubstantiated allegations of disloyalty, amounting to dismissal without just or authorized cause and without procedural due process. She is entitled to reinstatement, full backwages, and other monetary benefits.