G.R. No. 199166 - Begino vs. ABS-CBN Corp.

ABS-CBN Corporation (formerly ABS-CBN Broadcasting Corporation) operates as a television and radio broadcasting company with a Regional Network Group in Naga City.
Respondent Amalia Villafuerte served as Manager for ABS-CBN’s Regional Network Group.
Petitioners Nelson Begino and Gener Del Valle were engaged by ABS-CBN as Cameramen/Editors for TV broadcasting beginning in 1996.
Petitioners Ma. Cristina Sumayao and Monina Avila-Llorin were similarly engaged as reporters in 1996 and 2002, respectively.

Petitioners entered into Talent Contracts with ABS-CBN, regularly renewed over several years, with terms ranging from three months to one year.
Petitioners were issued Project Assignment Forms detailing project duration, budget, and daily technical requirements.
The contracts expressly stated that nothing therein established an employer-employee relationship.
Talent Contracts required petitioners to perform work according to ABS-CBN’s professional standards and policies, including compliance with regulatory bodies such as KBP.
Petitioners were prohibited from engaging in competing work without consent and worked on a results-oriented basis without fixed hours.
Petitioners were taxed as independent contractors and remunerated with talent fees per airing day, ranging from approximately Php273 to Php323.08.

Petitioners filed complaints before the National Labor Relations Commission (NLRC) claiming regular employee status, underpayment of benefits, illegal dismissal, and unfair labor practices.
They alleged performing necessary functions integral to ABS-CBN’s business, working under Villafuerte’s supervision, complying with company policies (attendance, punctuality), using company equipment, and subject to performance evaluations.
Petitioners contended they earned an average monthly income of Php7,000 to Php8,000, significantly less than regular employees who earned about Php21,773.
Respondents argued that petitioners were independent contractors or “talents,” engaged on a project or per-appearance basis without company control over work methods.
Respondents maintained the use of Talent Contracts and Project Assignment Forms to avoid establishing an employer-employee relationship.

Labor Arbiter Jesus Orlando QuiAones declared petitioners as regular employees based on the duration of service and control evidenced by exclusivity and prohibitions in Talent Contracts.
The NLRC affirmed this decision, rejecting respondents’ claims of non-employee status.
Respondents filed a Rule 65 petition for certiorari before the Court of Appeals (CA), which reversed the NLRC, ruling no employer-employee relationship existed, highlighting the contractual designation of talents, payment scheme, and lack of control over work methods.
Petitioners’ motion for reconsideration was denied by the CA.
Petitioners elevated the case to the Supreme Court via Rule 45 petition.

Whether the Court of Appeals erred in not dismissing respondents’ petition for certiorari, despite respondents’ failure to file a Notice of Appeal and to verify/certify their Memorandum of Appeal as required under NLRC Rules of Procedure.

Whether the Court of Appeals erred in ruling that there was no employer-employee relationship between petitioners and respondents, contrary to findings by the Labor Arbiter and NLRC and established jurisprudence.