Edu Manzano not entitled to P2.6M deducted by TV5 from his P63-M fees

Published August 25, 2021, 12:18 PM

by Rey Panaligan 

Court of Appeals

The Court of Appeals (CA) has denied the petition of actor and television host Eduardo “Edu” B. Manzano to reverse a 2019 trial court’s decision that dismissed his complaint involving P2.6 million against ABC Development Corporation (TV5).

In a decision promulgated last Aug. 17, the CA – reiterating jurisprudence – said: “It a settled rule that the law will not relieve a party from the consequences of the contract it entered with all the formalities and with full awareness of what they are doing.”

“The courts have no choice but to enforce such contract so long as it is not contrary to law, morals, good customs or public policy,” the CA also said in a decision written by Associate Justice Florencio M. Mamauag Jr. and concurred in by Associate Justices Zenaida T. Galapate Laguilles and Carlito B. Calpatura.

Case records showed that Manzano, represented by his talent manager June Torrejon Rufino (Rufino) of Tentra, Inc., signed at three-year talent agreement contract with TV5. From Sept. 1, 2011 to Aug. 31, 2014, Manzano was guaranteed a minimum talent fee of P63 million for three years.

Aside from on-camera acting, Manzano was also obliged to perform ancillary services such as on-air appearances, costume fittings, make-up calls, pre-production meetings, rehearsals, publicity and promotional trailers, mall shows, post-production activities, ad agency visits and participation in station ID shoots, among others.

On Feb. 6, 2014, TV5’s production team proposed a new game show called “Quiet Please” which required players to complete a challenge with the least noise within the time limit.

Manzano, through his talent manager, rejected hosting the show saying that “the show is not in keeping with Manzano’s personality and image.”

After a series of meetings, TV5 found Manzano’s position unacceptable. Thus, the television network decided to deduct P2.6 million from Manzano’s talent fees.

Despite Manzano’s protest through his talent manager, TV5 deducted from his talent fees P2.6 million in four equal instalments of P650,000 from April to July 2014.

Manzano claimed the deduction was arbitrary as he alleged that TV5 did not explain how the network arrived at the computation of the amount deducted from his fees.

When the issue was not resolved when referred to the Philippine Mediation Center, Manzano filed a case with the Makati City regional trial court (RTC).

On May 17, 2019, the RTC dismissed Manzano’s case “for lack of merit.” It ruled that it was Manzano who breached the talent agreement when he refused to host the program “Quiet Please.”

When the trial court denied his motion for reconsideration, Manzano elevated the issue before the CA.

In denying Manzano’s petition, the CA anchored its ruling on the provision of Article 1159 of the New Civil Code which states: “Obligations arising from contracts have the force of law between the contracting parties and should be complied with in good faith.”

The CA pointed out that “a contract, once perfected, has the force of law between the parties with which they are bound to comply in good faith and from which neither one may renege without the consent of the other.”

“After going over the evidence on record, the Court agrees with the ruling of the RTC that Manzano has unreasonably withheld his consent to participate in the show,” it said.

The CA also said:

“While it may be true that Manzano’s prominence and commercial value primarily depends on his personality and public image, he miserably failed to proffer any evidence that his hosting of the show will impair or diminish or even prejudice his credibility as an actor/celebrity host.

“In the same manner, Manzano’s (through Rufino) insistence that the success of his past shows was due to his ‘frequent banter’ with the players and the audience is untenable and unsubstantiated.

“Ultimately, there is no quantifiable or standard formula to determine the success or failure of the show. It is a business risk that both the network and talent must be willing to undertake.

“Moreover, denying consent solely on the basis of personal taste, convenience or sensibility is not commercially reasonable.

“WHEREFORE, the appeal is DENIED. The assailed Decision dated May 17, 2019 of the Regional Trial Court, Branch 132 of

Makati City, in Civil Case No. 15-254 is hereby AFFIRMED. SO ORDERED.”