Case Digest (G.R. No. 200434)
Facts:
Carmela C. Tiangco, Petitioner, vs. ABS-CBN Broadcasting Corporation, Respondent, G.R. No. 200434, December 06, 2021, the Supreme Court Third Division, Zalameda, J., writing for the Court.
Carmela C. Tiangco (petitioner) was engaged by ABS-CBN Broadcasting Corporation (ABS-CBN) beginning in 1986 as a talent/newscaster under a series of successive contracts and, in May 1994, under a three-year exclusive services Agreement between ABS-CBN and Mel & Jay Management and Development Corporation (MJMDC) that specified talent duties, exclusivity, and contract benefits (SSS, Medicare, 13th month pay, etc.). ABS-CBN issued a company Memorandum on 8 February 1995 barring on-air talents from appearing in commercials; petitioner appeared in a Tide commercial in December 1995 and was suspended for three months without pay on 16 January 1996.
Petitioner filed a complaint on 11 March 1996 for illegal dismissal, illegal suspension, and various monetary claims (backwages, separation pay, 13th month, travel, vacation benefits, stock shares, moral and other damages, and attorney’s fees). Petitioner and MJMDC also purported to rescind the May 1994 Agreement on 27 March 1996; ABS-CBN denied rescission, contending petitioner was an independent contractor.
Labor Arbiter Jose De Vera (29 April 1999) ruled for petitioner, finding the suspension and constructive dismissal illegal and awarding extensive monetary relief. ABS-CBN appealed to the National Labor Relations Commission (NLRC), which, citing the Supreme Court’s prior ruling in Sonza v. ABS-CBN Broadcasting Corporation (G.R. No. 138051, 10 June 2004), reversed the Labor Arbiter on 31 July 2006 and dismissed the case for lack of jurisdiction, holding petitioner was similarly situated to Sonza and thus an independent contractor.
Petitioner filed a certiorari petition to the Court of Appeals (CA). Pursuant to mediation, the parties executed a Partial Settlement Agreement dated 15 December 2011 that recited payment in full of specified monetary claims (salaries for the suspension period, 13th month pay, travel allowance, refund of ESOP contributions, signing bonus), withdrawal of certain bank deposits, a waiver limited to the specified monetary claims, and a “non-admission” clause preserving other issues for adjudication. The CA approved the Partial Settlement Agreement on 27 January 2012 (CA-G.R. SP No. 103584) and declared the remaining issue—whether the public respondent committed grave abuse in not inhibiting...(Pro-only)
Issues:
- Did the Partial Settlement Agreement finally settle all of petitioner’s monetary claims?
- Was petitioner an ABS-CBN employee or an independent contr...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)