G.R. No. 219508 September 14, 2021
ABS-CBN Broadcasting Corporation, Petitioner, vs. Kessler Tajanlangit, Vladimir Martin, Herbie Medina and Juan Paulo Nieva, Respondents.

FACTS

Petitioner ABS-CBN Broadcasting Corporation engaged individuals as “talents” or independent contractors for its program production, utilizing an Internal Job Market System (IJM) database for accreditation. Respondents Kessler Tajanlangit, Vladimir Martin, Herbie Medina, and Juan Paulo Nieva were hired as cameramen on various dates from 2003 to 2005. They were issued ABS-CBN ID cards, received wages on a per-hour basis via an ATM payroll account with deductions for taxes and statutory contributions, and were assigned work schedules by management. They worked under the supervision of ABS-CBN’s production supervisors and managers and were subject to company memoranda and disciplinary actions. Believing themselves to be regular employees deprived of benefits, respondents filed a complaint for regularization with money claims. After filing, ABS-CBN presented them with a sample contract requiring withdrawal of the case as a condition for continued work. Upon their refusal to sign, they were barred from company premises. The Labor Arbiter and the National Labor Relations Commission (NLRC) dismissed the complaint, finding no employer-employee relationship and classifying respondents as independent contractors. The Court of Appeals reversed this, finding an employer-employee relationship and declaring respondents’ dismissal illegal.

ISSUE

Whether an employer-employee relationship existed between ABS-CBN and the respondents, making them regular employees entitled to reinstatement and backwages.

RULING

Yes. The Supreme Court affirmed the Court of Appeals’ decision. Applying the four-fold test, the Court found that all elements of an employer-employee relationship were present: (1) ABS-CBN hired respondents; (2) they performed work as cameramen; (3) ABS-CBN had the power to dismiss them, as evidenced by their barring from premises after refusing the contract; and (4) most importantly, ABS-CBN exercised control over the means and methods of their work by assigning their shows, schedules, and supervisors, and by subjecting them to company rules and discipline. The payment of wages, deductions for contributions, and issuance of ID cards further indicated employee status. The IJM system did not negate this relationship but was a mechanism for engaging workers. Their dismissal for refusing to sign a contract that required withdrawing their case was illegal. They were declared regular employees entitled to reinstatement, full backwages, and benefits.