Case Digest (G.R. No. 200474) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Paragele et al. v. GMA Network, Inc., petitioners Henry T. Paragele and thirty others (camera operators and assistant camera operators) filed a consolidated Complaint with the Labor Arbiter claiming they were regular employees of GMA Network, Inc. and that their May 2013 terminations were illegal dismissals without just cause and without security of tenure guaranteed under the 1987 Constitution. They alleged they were directly engaged by GMA to perform tasks “necessary and desirable” to its broadcasting business, compensated per taping, and subject to GMA’s work schedules, equipment, and supervision. GMA countered that petitioners were mere “pinch-hitters or relievers” paid service fees as independent contractors, not employees, and thus had no right to regularization or reinstatement. Labor Arbiter Salinas dismissed the complaint for lack of proof of an employer-employee relationship. On appeal, the National Labor Relations Commission (NLRC) recognized the relationship but Case Digest (G.R. No. 200474) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petitioners’ Engagement and Work
- Petitioners Henry T. Paragele et al. were engaged by GMA Network, Inc. as camera operators (cameramen and assistant cameramen) on a per-taping basis, with “service fees” ranging from ₱750 to ₱1,500.
- GMA characterized petitioners as “pinch-hitters or relievers,” engaged only to augment its regular crew when additional workforce was needed for specific tapings.
- Procedural History
- Petitioners filed a consolidated complaint for regularization, later converted into one for illegal dismissal, non-payment of wages, and regularization.
- Labor Arbiter Salinas (Dec. 16, 2014) dismissed the complaint for failure to prove an employer-employee relationship.
- NLRC (Mar. 28, 2014) reversed in part: recognized the employment relationship but deemed only Roxin Lazaro regular (service > 1 year), classifying the rest as casual for lack of one-year service under Art. 295 of the Labor Code.
- CA (Mar. 3, 2017) denied petitioners’ Rule 65 certiorari petition, affirming the NLRC’s findings on regularization; CA denied reconsideration (Oct. 26, 2017).
- Petitioners filed a Rule 45 petition in the SC, challenging (a) existence of employer-employee relationship; (b) denial of regular status; and (c) legality of their dismissal.
Issues:
- Whether an employer-employee relationship existed between petitioners and GMA.
- Assuming such relationship, whether petitioners attained regular employment status.
- Assuming regular status, whether petitioners were illegally dismissed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)