Case Digest (G.R. No. 138051)
Facts:
Jose Y. Sonza v. ABS‑CBN Broadcasting Corporation, G.R. No. 138051, June 10, 2004, First Division, Carpio, J., writing for the Court. Petitioner Jose Y. Sonza (Sonza) sued respondent ABS‑CBN Broadcasting Corporation (ABS‑CBN) for unpaid remuneration and benefits allegedly due under a May 1994 Agreement, after Sonza (through his management company) terminated the relationship and filed a complaint with the Department of Labor and Employment, National Capital Region.In May 1994 ABS‑CBN entered into an Agreement with Mel & Jay Management and Development Corporation (MJMDC), which acted as the AGENT of Sonza (MJMDC was organized and controlled by Sonza and Carmela Tiangco). The Agreement engaged Sonza as exclusive talent to co‑host specified radio and television programs and provided for substantial monthly “talent fees” (P310,000 for year one; P317,000 thereafter), attendant benefits (SSS, PhilHealth, 13th‑month pay, insurance), and an exclusivity clause. On 1 April 1996 MJMDC/Sonza sent a notice of rescission to ABS‑CBN; Sonza filed a complaint on 30 April 1996 before the DOLE seeking salaries, separation pay, 13th month pay, signing bonus, travel allowance and ESOP proceeds.
ABS‑CBN moved to dismiss on the ground that no employer‑employee relationship existed and that the complaint was therefore beyond the jurisdiction of the Labor Arbiter. The Labor Arbiter (Donato G. Quinto, Jr.) initially denied the motion to dismiss (Dec. 2, 1996) but, after submission of position papers and affidavits, rendered a decision dated July 8, 1997 dismissing the complaint for lack of jurisdiction, concluding Sonza was a talent/independent contractor rather than an employee. The NLRC affirmed that decision in a 24 February 1998 Decision and denied reconsideration on 3 July 1998.
Sonza filed a petition for certiorari with the Court of Appeals (CA) on 6 October 1998. In CA‑G.R. SP No. 49190 the CA (Labitoria, J., with Elbinias and Buzon, JJ., concurring) dismissed the petition on 26 March 1999, finding the dispute to be essentially a breach of contract ...(Subscriber-Only)
Issues:
- Was the Labor Arbiter and the NLRC without jurisdiction over Sonza’s complaint?
- Was Sonza an employee of ABS‑CBN or an independent contractor under the May 1994 Ag...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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