Case Digest (G.R. No. 155207) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Wilhelmina S. Orozco v. The Fifth Division of the Court of Appeals, Philippine Daily Inquirer, and Leticia Jimenez Magsanoc (G.R. No. 155207, August 13, 2008), petitioner Wilhelmina S. Orozco was engaged by the Philippine Daily Inquirer (PDI) in March 1990 to write a weekly column titled “Feminist Reflections” in its Lifestyle section. She received ₱250 per column, later increased to ₱300, and submitted articles consistently—even during a six-month stay in New York City, when she mailed her contributions. On November 7, 1992, her column ceased publication after PDI’s editors, including respondent Leticia Jimenez Magsanoc and Chairperson Eugenia Apostol, decided to drop her without explanation. Believing she had been illegally dismissed as an employee, Orozco filed a complaint before the National Labor Relations Commission (NLRC) seeking reinstatement, back wages, 13th month pay, service incentive leave pay, moral and exemplary damages. The Labor Arbiter ruled in her favor, fi Case Digest (G.R. No. 155207) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Engagement of Petitioner
- In March 1990, Philippine Daily Inquirer (PDI) engaged Wilhelmina S. Orozco as a weekly columnist for its Lifestyle section, paying her ₱250.00 per column (later increased to ₱300.00). She submitted articles weekly and even during a six-month stay in New York City.
- On November 7, 1992, her column appeared for the last time. She was informed by her editor, Lita T. Logarta, that Editor in Chief Leticia Magsanoc and PDI Chairperson Eugenia Apostol decided to discontinue her column without clear justification.
- Procedural History
- Labor Arbiter Decision (October 29, 1993) – Found Orozco to be a PDI employee, ordered her reinstatement with backwages, 13th month pay, and service incentive leave pay; dismissed other claims. NLRC Second Division (August 23, 1994) affirmed, noting PDI’s failure to post appeal bond and no substantial error in finding control over Orozco’s work.
- Court of Appeals (June 11, 2002; MR denied September 11, 2002) – On certiorari, set aside NLRC decision and dismissed Orozco’s complaint, holding she was an independent contributor, not an employee.
- Supreme Court Proceedings – Petition for review under Rule 45 filed; SC initially required PDI to post bond (Resolution, April 29, 2005), which PDI did on January 25, 2007. SC then took up the merits.
Issues:
- Whether a newspaper columnist constitutes an employee of the publishing newspaper under Philippine labor law.
- If employment exists, whether petitioner was illegally dismissed by PDI.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)