Title
ABS-CBN Corporation vs. Magno
Case
G.R. No. 203876
Decision Date
Mar 29, 2022
Magno, a regular ABS-CBN employee, claimed constructive dismissal after resigning and joining another network. The Supreme Court ruled she was a regular employee but not constructively dismissed, ordering reinstatement without backwages.

Case Summary (G.R. No. L-21186)

Key Dates and Procedural Posture

Relevant filings and rulings included: Labor Arbiter decision (April 13, 2011) dismissing Magno’s complaint; NLRC resolutions (August 24, 2011 and October 28, 2011) affirming the Labor Arbiter; Court of Appeals decision (June 29, 2012) reversing and granting relief to Magno; and the Supreme Court’s review (petition for certiorari) resulting in reversal of the CA decision. The Court applied legal standards under the 1987 Philippine Constitution and relevant provisions of the Labor Code (notably Articles 279–280 as cited in the decision and established jurisprudence).

Antecedent Facts

ABS-CBN created the IJM system (a database/accreditation system for technical/creative personnel) in 2002 to staff its in-house productions. Magno, a long-serving VTR Playback Operator, was placed under IJM without her consent. After Wowowee was replaced by PWNW (July 31, 2010), Magno worked on PWNW. Following an episode where management learned she attended a dinner hosted by Revillame, Magno claims she was pressured to resign and subsequently submitted a resignation letter dated August 16, 2010. She later took employment with Revillame’s new show on another network. On September 13, 2010, Magno filed a complaint alleging illegal dismissal, regularization, unpaid benefits, moral and exemplary damages, and attorneys’ fees.

Claims and Contentions of the Parties

Magno’s contentions: she was a regular employee of ABS-CBN (having worked over 18 years and satisfying the four-fold test), she was constructively dismissed when pressured to resign and denied access to assignments, and her resignation letter referred only to leaving the PWNW program, not ABS-CBN. ABS-CBN’s contentions: Magno was not an employee but an independent contractor under the IJM; the company did not exercise the requisite control to establish employment; her resignation was voluntary; and, absent an employment relationship, her claims for illegal dismissal and statutory benefits lacked merit.

Labor Arbiter and NLRC Rulings

Labor Arbiter: Dismissed Magno’s complaint for lack of cause/action, finding she failed to prove employment status since ABS-CBN did not exercise determinative control over means and methods of her work.
NLRC: Denied Magno’s appeal and affirmed the Labor Arbiter’s decision, noting her service engagement was not exclusive and that she was not prohibited from working for other entities; thus, no employer-employee relationship and no constructive dismissal.

Court of Appeals Ruling

The Court of Appeals granted Magno’s petition for certiorari and reversed the NLRC and Labor Arbiter, holding that Magno was a regular employee because her services were necessary and desirable to ABS-CBN’s business and because documentary evidence and other “badges” of employment supported an employer-employee relationship. The CA interpreted Magno’s resignation letter as limited to her PWNW assignment and found constructive dismissal when ABS-CBN allegedly excluded her from its workforce without due process. The CA ordered reinstatement with backwages, awarded moral and exemplary damages, and attorney’s fees.

Issues Presented to the Supreme Court

  1. Whether an employer-employee relationship existed between ABS-CBN and Magno.
  2. Whether Magno was constructively dismissed.

Applicable Legal Standards

  • Constitutional and statutory framework: the decision applied standards consistent with the 1987 Constitution and the Labor Code, including the rules on employment status and protection against unjust dismissal.
  • Four-fold test for employer-employee relationship: (1) selection and engagement of employees; (2) payment of wages; (3) power of dismissal; and (4) power to control the employee’s conduct and the means and methods of work. No single factor is determinative; relevant documentary and circumstantial evidence (IDs, pay slips, government contributions, payroll treatment, supervisory control) are admissible and material.
  • Article 280 jurisprudence: workers who perform functions necessary and desirable to the employer’s trade/business may be regular employees despite label or contract form.
  • Constructive dismissal: requires proof by clear and convincing evidence that resignation was made under compulsion or circumstances approximating compulsion; bare or self-serving allegations are insufficient. When an employer asserts voluntariness of resignation, the employer bears the burden to prove resignation was voluntary.
  • Abandonment: involves deliberate and unjustified refusal to resume employment with both absence without justification and a clear intention to sever the relationship; abandonment is incompatible with a constructive dismissal claim.

Supreme Court’s Analysis on Employment Status

The Supreme Court applied the four-fold test and relied on precedent (notably Del Rosario v. ABS-CBN and Nazareno) that IJM talents performing functions integral to ABS-CBN’s production business are regular employees. The Court found persuasive the documentary and circumstantial evidence showing employer-employee indicia: direct hiring by ABS-CBN, issuance of company identification, salary payments and payslips bearing ABS-CBN’s corporate name, ABS-CBN’s registration and contributions in government agencies (PhilHealth, tax records, BIR forms, Certificates of Compensation Payment/Tax Withheld), issuance of a Certification of Employment, and ABS-CBN’s control over assignments, transfers, schedules, and supervision. On the totality of evidence and consistent jurisprudence, the Court concluded Magno was a regular ABS-CBN employee.

Supreme Court’s Analysis on Constructive Dismissal

Although finding Magno to be a regular employee, the Court reversed the CA on the constructive dismissal finding. The Court emphasized the high evidentiary standard: constructive dismissal must be shown by clear and convincing evidence. The Court found Magno’s allegations unsubstantiated: she did not identify the superiors who allegedly forced her resignation, provided no particulars of coercion, and did not present evidence that she was denied access to assigned work sites. The resignation letter’s cordial tenor and expression of gratitude cast doubt on a coerced resignation; its language also made ambiguous whether she resigned from a specific program or from ABS-CBN generally. The Court further noted statements in the Complaint-in-Intervention indicating that Magno and colleagues voluntarily resigned to follow Revillame after the cancellation of Wowowee, supporting voluntariness. Given the lack of clear and c

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