Facts:

The case involves ABS-CBN Broadcasting Corporation as the petitioner and Kessler Tajanlangit, Vladimir Martin, Herbie Medina, and Juan Paulo Nieva as the respondents. The events leading to this case began when the respondents, who were engaged as cameramen by ABS-CBN, filed a complaint for illegal dismissal, unfair labor practice, and monetary claims against the company. The complaint was filed before the National Labor Relations Commission (NLRC) after the respondents were barred from entering the company premises and were removed from work schedules following their refusal to sign new employment contracts. The respondents claimed they had been regular employees of ABS-CBN since their hiring between July 2003 and April 2005, despite the absence of written contracts. They were issued identification cards, received wages directly from ABS-CBN, and were subject to the company's control and supervision. The Labor Arbiter dismissed their complaints on March 30, 2011, ruling t...

Facts:

Background of ABS-CBN’s Business and Employment Practice

• ABS-CBN Broadcasting Corporation, primarily engaged in radio and television broadcasting, routinely produced its own programs despite lacking a full-time creative and technical workforce.
• To address this, ABS-CBN employed independent contractors—referred to as “talents”—such as directors, actors, scriptwriters, and production/technical staff, for specific programs.
• In 2002, the company implemented the Internal Job Market (IJM) System, a database designed to list accredited technical and creative manpower along with their competency ratings and corresponding rates, thereby streamlining recruitment and negotiation.

Nature and Conditions of Engagement

• The IJM System allowed talents to voluntarily undergo additional training and accreditation; however, signing up did not bind them exclusively to ABS-CBN.
• When a project arose, the producer would review the IJM database, notify the associated talent, and offer them work with no long-term or exclusive commitment.
• Despite this non-exclusive arrangement, the records evidence that talents (including the respondents) were issued company identification cards, received periodic wage payments directly from the company (with statutory deductions), and were subjected to a work schedule set by the management.

The Dispute and Filing of Complaints

• In June 2010, ABS-CBN offered employment contracts to the respondents for positions as remote cameramen; instead of opting for these contractual terms, the respondents proceeded to file complaints with the National Labor Relations Commission (NLRC).
• The respondents claimed that they had been regularly employed as cameramen—engaged from July 2003 to April 2005—with ABS-CBN without a written employment contract, but through a document titled “Accreditation in the Internal Job Market System.”
• Evidence submitted by the respondents included copies of their ID cards, payslips reflecting hourly wage computations (with corresponding deductions for taxes and social contributions), income tax returns (ITRs), work schedules, and memoranda regarding disciplinary actions, all suggesting an employer-employee relationship rather than that of independent contractors.

Judicial and Administrative Proceedings

• At the Labor Arbiter level, the consolidated complaints for illegal dismissal, unfair labor practice, and monetary claims were dismissed on the ground that no employer-employee relationship existed.
• The NLRC, upon review, affirmed the Labor Arbiter’s decision by holding that the respondents’ work arrangement was that of independent contractors given the minimal control exercised by ABS-CBN.
• The respondents then obtained relief by filing a Petition for Certiorari under Rule 65 before the Court of Appeals (CA), which reversed the NLRC’s rulings—finding that all elements establishing an employer-employee relationship were met.
• Consequently, the CA ordered the reinstatement of the respondents, payment of full backwages and other statutory benefits, and attorney’s fees, while declaring the dismissals illegal.
• ABS-CBN subsequently filed a Motion for Reconsideration with the CA, which was denied, prompting the present Petition for Review on Certiorari under Rule 45 before the Supreme Court.

Issue:

Determination of Employment Status

• Whether or not the Court of Appeals committed an error in reversing the NLRC’s ruling by establishing that an employer-employee relationship existed between ABS-CBN and the respondents.
• Whether the evidentiary record sufficiently proved that the respondents, though initially engaged as “talents” through the IJM System, functioned effectively as regular employees.

Application of the Four-Fold Test

• Whether the application of the four-fold test—considering the selection/engagement process, mode of wage payment, power of dismissal, and degree of control—correctly supports the respondents’ claim as employees.
• Whether the distinct factual differences between the instant case and previous cases (e.g., Sonza) warrant a different categorization of the respondent’s status.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)