G.R. No. 205498 - GMA Network, Inc. vs. Cruz-Valdes

On June 1, 1998, GMA Network, Inc. (GMA) hired Luisita “Luchi” Cruz-Valdes as Production Unit Manager. In 2001, they executed a Talent Agreement engaging her as host, writer, reporter, and segment host for several GMA news programs, with detailed exclusivity, confidentiality, and consent requirements, and provisions for termination, suspension, and injunctive relief.
Key provisions included paragraph 4 (no services for other productions without GMA’s prior written consent), paragraph 5 (no endorsements without consent), paragraph 6 (non-disclosure and no public criticism), and paragraphs 15–17 (equitable remedies for breach, termination at GMA’s discretion, and non-compete option).

On October 15, 2001, Cruz-Valdes tendered irrevocable resignation as Production Unit Manager effective November 15, 2001. GMA advised her to avail terminal leave, relieved her of duties, replaced her on programs, terminated her email, and stopped paying talent fees. She surrendered company-issued items by November 2001.
On November 8, 2001, GMA’s counsel alleged her resignation breached the Talent Agreement and demanded compliance with its terms. On December 14, 2001, ABS-CBN hired Cruz-Valdes as Vice President for News.

December 2001: GMA filed for breach of contract, nullity, tort, injunction, and damages. RTC granted preliminary injunction on December 28, 2001; Court of Appeals (CA) upheld it in the injunction case.
June 23, 2008: RTC after trial dismissed GMA’s complaint, found no breach, and awarded Cruz-Valdes ₱2 million actual damages. July 25, 2012: CA denied GMA’s appeal, affirmed no breach, no tortious interference, and actual damages; January 17, 2013: CA denied motion for reconsideration. GMA filed a Rule 45 Petition for Review on Certiorari.

Whether this Court should entertain a Rule 45 petition raising questions of fact.
Whether Cruz-Valdes breached her Talent Agreement by working for ABS-CBN without GMA’s written consent.
Whether ABS-CBN is liable for tortious interference when it hired Cruz-Valdes.
Whether Cruz-Valdes is entitled to ₱2,000,000 actual damages for lost income.
Whether GMA is entitled to liquidated damages, exemplary damages, and attorney’s fees.