G.R. No. 205498 , May 10, 2021
GMA Network, Inc., Petitioner, vs. Luisita Cruz-Valdes and ABS-CBN Broadcasting Corporation, Respondents.

FACTS

Petitioner GMA Network, Inc. (GMA) hired respondent Luisita “Luchi” Cruz-Valdes as a production unit manager in 1998. In 2001, they entered into a Talent Agreement, engaging Cruz-Valdes as a talent for specific programs (host for “I-Witness,” writer for “Saksi,” reporter for “Brigada Siete,” and segment host for “Unang Hirit”). The agreement contained exclusivity clauses prohibiting her from rendering services for other entities without GMA’s prior written consent and allowed GMA to terminate the agreement under specific conditions. On October 15, 2001, Cruz-Valdes tendered her irrevocable resignation as Production Unit Manager for News, effective November 15, 2001, citing a new opportunity. Upon receiving the resignation, GMA’s Vice President advised her to avail of terminal leave and told her she no longer needed to report. The following day, she was informed she had been replaced as host for “I-Witness” and “Unang Hirit.” GMA also required her to turn over company-issued items, terminated her email, and stopped paying her talent fees in November 2001. On November 8, 2001, GMA’s counsel sent a letter claiming her resignation breached the Talent Agreement. On November 15, 2001, respondent ABS-CBN Broadcasting Corporation hired Cruz-Valdes as its Vice President for News. GMA filed a Complaint for breach of contract, declaration of nullity of contract, tort, injunction, and damages. The Regional Trial Court granted a Writ of Preliminary Injunction enjoining Cruz-Valdes and ABS-CBN from continuing their contract. After trial, the Regional Trial Court dismissed GMA’s complaint and ordered GMA to pay Cruz-Valdes actual damages. The Court of Appeals affirmed the decision. GMA elevated the case via a Petition for Review on Certiorari.

ISSUE

1. Whether Cruz-Valdes breached the Talent Agreement with GMA.
2. Whether ABS-CBN is liable for tortious interference with contractual relations.
3. Whether the award of actual damages to Cruz-Valdes was proper.

RULING

1. No, Cruz-Valdes did not breach the Talent Agreement. The Supreme Court held that Cruz-Valdes resigned only from her position as a production unit manager, not as a talent under the Talent Agreement. The resignation letter was addressed to the News Division and specifically referred to her managerial role. Furthermore, GMA, through its own actions, rendered it impossible for Cruz-Valdes to perform her obligations under the Talent Agreement. GMA replaced her in her talent roles, required her to surrender company property necessary for her work, terminated her email access, and stopped paying her talent fees. A party who prevents the fulfillment of a condition cannot insist on the other party’s breach. The Talent Agreement also permitted her to work for another entity with GMA’s consent, and GMA did not show it withheld consent unreasonably upon being informed of her new opportunity.
2. No, ABS-CBN is not liable for tortious interference. To be liable, the defendant must have acted with malice or without a legitimate business purpose. The Court found that ABS-CBN hired Cruz-Valdes for a legitimate reason—to be its Vice President for News, an executive position involving training and supervision, which was different from her talent roles at GMA. ABS-CBN did not hire her to damage GMA’s operations. There was no evidence of malicious intent to injure GMA.
3. Yes, the award of actual damages was proper. Cruz-Valdes was entitled to compensation for the earnings she was deprived of due to GMA’s actions and the injunction. This included talent fees from GMA for the period she was prevented from working (October 15, 2001 to August 20, 2002) amounting to P800,000.00, and the salary she would have earned from ABS-CBN as Vice President for News from November 15, 2001 to August 20, 2002 amounting to P1,785,000.00, for a total of P2,585,000.00. The Regional Trial Court correctly deducted the P500,000.00 bond posted by GMA for the injunction, resulting in the net award of P2,000,000.00. The Supreme Court affirmed this computation.
The Petition for Review on Certiorari was DENIED. The Decision and Resolution of the Court of Appeals were AFFIRMED.