Case Digest (G.R. No. 205498)
Facts:
GMA Network, Inc. v. Luisita Cruz‑Valdes and ABS‑CBN Broadcasting Corporation, G.R. No. 205498, May 10, 2021, the Supreme Court Third Division, Leonen, J., writing for the Court.Petitioner GMA Network, Inc. (GMA) employed Luisita "Luchi" Cruz‑Valdes on June 1, 1998 as a production unit manager and engaged her under a 2001 Talent Agreement to serve as host, writer, reporter, and segment host on several GMA programs. The Talent Agreement contained exclusivity and confidentiality clauses (notably paragraph 4 requiring prior written consent before rendering services for any other broadcast production), a clause on endorsements (paragraph 5), non‑disclosure obligations (paragraph 6), remedies for breach including injunctive relief (paragraph 15), and GMA’s option to terminate (paragraph 16) or reassign the talent (paragraph 17).
On October 15, 2001 Cruz‑Valdes tendered a resignation letter stating she resigned as Production Unit Manager effective November 15, 2001 because “a new opportunity has opened up.” GMA’s vice‑president for News and Public Affairs, Marissa Flores, advised her to avail of terminal leave and told her she no longer needed to report for work. GMA replaced Cruz‑Valdes on her hosting assignments, required her to return company property (radios, phones, IDs, manuals, files), terminated her company email, and in November 2001 stopped paying her talent fees. On November 8, 2001 GMA’s counsel sent Cruz‑Valdes a letter asserting her resignation breached the Talent Agreement and demanding compliance with its restrictive clauses.
On November 15, 2001 ABS‑CBN Broadcasting Corporation (ABS‑CBN) hired Cruz‑Valdes as Vice President for News. GMA filed a complaint for breach of contract, declaration of nullity, tort, injunction, and damages in the Regional Trial Court (RTC) and secured a writ of preliminary injunction on December 28, 2001 enjoining Cruz‑Valdes and ABS‑CBN from proceeding with the employment; GMA posted a P500,000 bond. Cruz‑Valdes and ABS‑CBN sought certiorari from the Court of Appeals (CA) to challenge the injunction, but the CA dismissed the petition and upheld the injunction.
After trial on the merits, in its June 23, 2008 decision the RTC dismissed GMA’s complaint and awarded Cruz‑Valdes P2,000,000 as actual damages. GMA appealed to the CA. On July 25, 2012 the CA (Eighth Division) affirmed the RTC: it held Cruz‑Valdes resigned only as an employee (not as talent), that paragraph 4 of the Talent Agreement permitted other engagements with GMA’s written consent, and that GMA’s own actions rendered performance impossible and amounted to a unilateral termination of the Talent Agreement; the CA also found ABS‑CBN’s hiring legally justified and not malicious, and affirmed the award of actual damages (after deducting the bond). The CA denied GMA’s motion for reconsideration on January 17, 2013.
GMA filed a Pe...(Subscriber-Only)
Issues:
- Should the Supreme Court entertain this Rule 45 petition that raises questions of fact?
- Did Luisita Cruz‑Valdes breach her Talent Agreement with GMA when she worked as ABS‑CBN’s Vice President for News?
- Is ABS‑CBN liable for tortious interference when it hired Cruz‑Valdes?
- Is Cruz‑Valdes entitled to actual damages of P2,000,000.00 (and related computation) for lost income?
- Is GMA entitled to liquidated damages, ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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