Case Digest (G.R. No. 238104)
Facts:
- Odelon Alvarez Miranda is the petitioner against the Social Security Commission (SSC) and the Social Security System (SSS), represented by Carina L. Catahan.
- The case originated on July 20, 2006, when the SSS filed a petition for unpaid contributions and penalties against Onise Marketing (Onise) and Miranda, registered as SSC Case No. 7-16922-06.
- The SSS claimed Onise and Miranda failed to remit SSS contributions from February 2002 to March 2006, totaling P113,896.26.
- The SSS sought a Warrant for the Sheriff to levy and sell properties of Onise and Miranda to satisfy the liabilities.
- On February 5, 2007, the SSC declared both parties in default for not filing an answer.
- On April 24, 2013, the SSC held them liable for unpaid contributions of P16,659.00 and penalties of P44,137.58, totaling P60,796.58.
- Despite the default, partial payments were made, indicating acknowledgment of liabilities.
- A Writ of Execution was issued on July 15, 2015, followed by a Notice of Garnishment on February 26, 2016.
- On June 21, 2016, Miranda filed a motion to annul the April 24, 2013 resolution and quash the Writ of Execution, claiming lack of jurisdiction due to non-receipt of summons.
- The SSC denied the motion, asserting Miranda had received the summons and failed to update his address.
- Miranda's motion for reconsideration was also denied, leading him to file a petition for certiorari and prohibition with the Court of Appeals (CA).
- The CA partly granted his petition on November 20, 2017, annulling the orders denying the motion to quash but upholding the SSC's resolution on liability.
- Miranda's subsequent motion for partial reconsideration was denied on March 12, 2018.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the SSC properly acquired jurisdiction over Miranda due to valid service of summons.
- The execution of the SSC's April 24, 2013 resolution was deemed valid and final.
- The CA's rulin...(Unlock)
Ratio:
- The Supreme Court noted that the question of whether Miranda received the summons was a factual issue not typically resolved in a certiorari appeal.
- The SSC provided substantial evidence, including proof of service and acknowledgment of partial payments, in...continue reading
Case Digest (G.R. No. 238104)
Facts:
The case involves Odelon Alvarez Miranda as the petitioner against the Social Security Commission (SSC) and the Social Security System (SSS), represented by Carina L. Catahan, as respondents. The events leading to this case began on July 20, 2006, when the SSS filed a petition for the collection of unpaid SSS contributions and penalties against Onise Marketing (Onise) and Miranda. This petition was registered as SSC Case No. 7-16922-06. The SSS claimed that Onise, as an employer registered with the SSS, and Miranda, as its Manager/Owner, failed to remit the SSS contributions for their employees from February 2002 to March 2006, amounting to P113,896.26, which was subject to final computation. The SSS sought a Warrant for the Sheriff to levy and sell properties of Onise and Miranda to satisfy the liabilities.
On February 5, 2007, the SSC declared both Onise and Miranda in default due to their failure to file an answer. Subsequently, on April 24, 2013, the SSC issued a resolution holding them liable for unpaid contributions totaling P16,659.00 and penalties amounting to P44,137.58, culminating in a total of P60,796.58. The SSC noted that despite the default declaration, partial payments had been made by Onise and Miranda, indicating acknowledgment of their liabilities. A Writ of Execution was issued on July 15, 2015, followed by a Notice of Garnishment on February 26, 2016.
On June 21, 2016, Miranda filed an urgent motion to annul the April 24, 2013 resolution and quash the Writ of Execution, claiming lack of jurisdiction as he had not received any summons or notices. The SSC denied this motion, asserting that Mi...