In G.R. No. 266552 (Escauriaga v. Fitness First, Phil., Inc.), the Supreme Court's Second Division, through Associate Justice Amy C. Lazaro-Javier, applied the four-fold test governing the employer-employee relationship to determine whether several fitness trainers were employees of Fitness First Phil, Inc.

Under this test, four factors must be proven: (a) the employer's selection and engagement of the employee; (b) the payment of wages; (c) the power to dismiss; and (d) the power to control the employee's conduct, which the Supreme Court stressed as the most significant factor. In declaring the trainers to be regular employees of Fitness First, the Supreme Court underscored that the gym held the power to dismiss the trainers when it became manifest that the latter were unqualified or unfit to discharge their duties or failed to comply with the monthly Minimum Performance Standards under their Freelance Personal Trainer Agreement.

Moreover, the trainers also performed tasks necessary and desirable for Fitness First's principal business of providing health programs/packages and physical training to its clients. To ensure the quality of services that Fitness First provides, the trainers were required to attend all educational training sessions and other relevant events. The Supreme Court further noted that Fitness First even kept track of the trainers' performance, with some of them being lauded for their exemplary work. The Supreme Court also held that even when applying the economic dependence test, where the circumstances of the entire economic activity are considered in determining the relationship between employer and employee, the conclusion would still be the same.