Fuji TV vs. Espiritu, G.R. Nos. 204944-45, Dec.

3, 2014

Facts: Fuji Television Network engaged Arlene Espiritu as a news correspondent for
a term of 1 year. However, her contract was successively renewed on a yearly basis
with salary adjustment upon every renewal. Arlene was later diagnosed with lung
cancer. After several communications, Arlene and Fuji signed a non-renewal contract
stipulating that her contract would no longer be renewed after its expiration. It also
provided that the parties release each other from liabilities and responsibilities
under the employment contract. The next day, Arlene filed a complaint for illegal
dismissal.

Issue: What is the level of constitutional regulation and protection afforded to

contracts of employment? Are there factors that may vary the level of protection?

Ruling: Contracts of employment have a higher level of regulation because they

are impressed with public interest. Article XIII, Section 3 of the 1987 Constitution
provides full protection to labor. Likewise, such contracts are also subject to
regulatory review by the labor tribunals and courts of law.

Yes, the level of protection to labor should vary from case to case; otherwise, the
state might appear to be too paternalistic in affording protection to labor. The level
of protection to labor must be determined on the basis of the nature of the work,
qualifications of the employee, and other relevant circumstances.