Title
Haveria vs. Social Security System
Case
G.R. No. 181154
Decision Date
Aug 22, 2018
Haveria, a former SSS employee, claimed SSS membership via SSSEA employment. Courts ruled his coverage erroneous, treating SSSEA contributions as voluntary to meet pension eligibility, denying compulsory benefits.

Case Digest (G.R. No. 181154)

Facts:

  • Employment and Membership Background
    • Ramchrisen H. Haveria was employed with the Social Security System (SSS) from May 1958 to July 1984.
    • During his employment, he became a member of and was elected as an officer/treasurer of the SSS Employees’ Association (SSSEA).
    • The SSSEA reported him as an employee for SSS coverage, and his membership was approved, with monthly contributions remitted from May 1966 to December 1981.
  • Subsequent Employment and Contributions
    • After leaving the SSS, Haveria worked for private entities:
      • Stop Light Diners from July 1989 to December 1996; and
      • First Ivory Pharma Trade from January to March 1997.
    • During his tenure with these private employers, he made a total of 281 monthly contributions.
    • His retirement age (60 years old) was reached on August 8, 1997.
    • While covered under the SSS, Haveria availed various benefits including salary loans, a housing loan (1968), partial disability benefit (1995), and retirement benefits from August 1997 until July 2002.
  • Suspension of Benefits and Filing of Petition
    • In June 2002, Haveria received a letter from the SSS ordering the suspension of his retirement benefits.
      • The letter based its directive on a legal opinion concerning separate claims by Genaro Ledesma and Filemon Pahuyo, who were also former SSS employees and SSSEA officers.
      • The opinion stated that, lacking an employment relationship with the SSSEA, such persons were not entitled to benefits under the Social Security Law (R.A. No. 8282).
    • Prompted by this suspension, Haveria filed a letter-petition with the Social Security Commission (SSC) for:
      • The declaration of the validity of his SSS membership; and
      • The restoration of his monthly pension.
    • He argued that his registration and contributions were valid, asserting that even if his registration was flawed, equity and estoppel should entitle him to retirement benefits.
  • The SSC Resolution and Subsequent Motions
    • On December 7, 2005, the SSC issued a Resolution holding that Haveria’s coverage under the SSS was erroneous because:
      • Haveria was not an employee of the SSSEA but rather of the SSS, a government agency.
      • There was no employment relationship between Haveria and the SSSEA, as labor unions or associations are not regarded as employers.
      • Haveria could not claim coverage under the expanded scheme for self-employed workers because he claimed to be an employee of the SSSEA.
    • The SSC noted that although Haveria made 281 monthly contributions, only 93 were valid as compulsory contributions:
      • 90 contributions while employed by Stop Light Diners; and
      • 3 contributions with First Ivory Pharma Trade.
    • In the interest of justice, the SSC ruled that contributions remitted by the SSSEA be considered voluntary contributions to help meet the minimum requirement of 120 monthly contributions for pension eligibility.
    • Haveria’s motion for reconsideration (MR) was denied in an Order dated November 15, 2006.
  • Court of Appeals (CA) Decision and the Petition for Review
    • The CA affirmed the SSC Resolution and Order, emphasizing:
      • Haveria was not an employee of the SSSEA, but merely an officer of the association while being a full-time government employee with the SSS.
      • The error regarding wrongful registration as a compulsory member was based on Haveria’s misrepresentation and was not subject to estoppel against a government agency.
      • Administrative findings, if supported by substantial evidence, deserve great weight and are entitled to deference.
    • Haveria then filed a petition for review on certiorari before the Supreme Court, contending that:
      • His membership in the SSS was valid and he had been erroneously deprived of his pension benefits; and
      • The principles of equity, estoppel, and social justice warranted a ruling in his favor.

Issues:

  • Validity of Membership and Coverage
    • Whether Haveria’s inclusion as a compulsory member of the SSS under the claim of employment with the SSSEA is valid, given that his actual employment was with the SSS.
    • Whether the contributions remitted during his alleged SSSEA employment can be credited toward the required minimum for pension benefits.
  • Application of Estoppel Against the SSS
    • Whether Haveria can invoke the doctrine of estoppel against the SSS based on the erroneous representation that he was an employee of the SSSEA.
    • The issue of whether a government agency like the SSS is estopped by representations made by its agents or by third parties (such as the SSSEA).
  • Deference to Administrative Findings
    • Whether the CA and SSC’s factual determinations and findings—regarding both the non-existence of an employment relationship with SSSEA and the classification of contributions—merit deference and should be upheld.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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