G.R. No. 226846 - People vs. Macaranas y Ferdez

Petitioner, Dr. Mary Jean P. Loreche-Amit, began working with Cagayan De Oro Medical Center, Inc. (CDMC) in May 1996 as an Associate Pathologist under the late Dr. Jose N. Gaerlan.
Following the demise of Dr. Gaerlan, the Board of Directors of CDMC formally appointed petitioner as Chief Pathologist for a five-year term or until May 15, 2011.

On June 13, 2007, CDMC’s Board of Directors passed a resolution recalling petitioner’s appointment as Chief Pathologist.
Petitioner contended that the recall was instigated by an attempt to oust her from the hospital, attributing the motive to Dr. Hernando Emano’s alleged request for her assistance in qualifying his daughter, Dr. Helga Emano-Bleza, as a pathologist, despite the latter’s failure to pass the clinical pathology examination.

Subsequent to the refusal to assist, Dr. Francisco Oh issued an Inter-Office Memorandum which warned that working without proper permission would be treated as absence without official leave, and printing duplicate copies without endorsement was regarded as stealing.
Petitioner, in reaction, slammed the memorandum on the wall and labeled Dr. Oh as an “irrational man.” This led to her receiving another memorandum citing alleged conduct unbecoming and insubordination, urging her to explain why her appointment should not be revoked.
Ultimately, a Memorandum was issued which formally recalled her appointment.

Respondents (Dr. Emano, Dr. Oh, and CDMC) argued that petitioner was never hired as an employee; rather, she had been assisting Dr. Gaerlan in managing the laboratory while concurrently working for other hospitals (Capitol College Hospital and J.R. Borja Memorial Hospital).
The Labor Arbiter, in a Decision dated March 31, 2008, dismissed petitioner’s complaint for illegal dismissal on the ground that she was a corporate officer, and thus the matter fell within the jurisdiction of the Regional Trial Court under R.A. No. 8799.
The National Labor Relations Commission (NLRC) in its Resolution dated March 31, 2009, affirmed the Labor Arbiter’s ruling, reiterating that there was no employer-employee relationship between petitioner and CDMC, since her position was considered intra-corporate.
The Court of Appeals (CA) in its Decision dated August 3, 2012, dismissed petitioner’s petition and echoed the findings of the Labor Arbiter and the NLRC, with the subsequent Resolution for reconsideration (dated April 12, 2013) likewise dismissing her motion.

Whether the labor tribunals (Labor Arbiter and NLRC) had jurisdiction over petitioner’s complaint for illegal dismissal, considering her alleged status as a corporate officer.

Whether petitioner, by reason of her appointment through a Board resolution, qualifies as a corporate officer under the Corporation Code or the by-laws of CDMC.
Whether the characteristics of her work – including compensation based on gross receipts and working for multiple hospitals – indicate an employee or an independent service provider.

Whether the four-fold test (selection and engagement, payment of wages, power of dismissal, and power to control the employee’s conduct) affirms the existence of an employer-employee relationship.
Whether the economic reality test, focusing on the worker’s economic dependence on the employer, supports classifying petitioner as an employee.