Case Digest (G.R. No. 195382)
Facts:
Orion Water District, represented by its General Manager, Crispin Q. Tria, et al. v. The Government Service Insurance System (GSIS), G.R. No. 195382, June 15, 2016, Supreme Court Third Division, Reyes, J., ponente.The case arose from a Complaint for Collection of Sum of Money and Damages filed on April 4, 2006 by GSIS against Orion Water District (OWD), a government-owned and controlled corporation (GOCC), and several of its officers (Manager Bener E. Guzman; Head of Agency Ceferina Macdon; Finance Officer Yolanda S. Urbano; Cashier Cecile B. Swim) in the Regional Trial Court (RTC) of Pasay City, Branch 115, Civil Case No. 06-0417 CFM. GSIS alleged that OWD failed to remit employees’ shares of life and retirement premium contributions for the period July 1993 to July 31, 2000, totaling P551,407.16, despite repeated demands, the last of which was received by OWD’s manager on November 21, 2002.
On March 13, 2007, OWD moved to dismiss for lack of subject-matter jurisdiction, arguing that disputes between GOCCs must be administratively settled by the Secretary of Justice under Sections 66–70, Chapter 14, Book IV of E.O. No. 292. The RTC denied the motion on March 28, 2008 and denied reconsideration on June 27, 2008, finding the defendants had not shown the controversy arose from interpretation or application of statutes, contracts, or agreements.
OWD (now represented by GM Crispin Tria after Guzman’s resignation) filed a petition for certiorari with the Court of Appeals (CA) on September 22, 2008, claiming grave abuse of discretion by the RTC and invoking the administrative settlement scheme under E.O. No. 292 (appealable under Rule 43). The CA, in a Decision dated October 14, 2010 (authored by Associate Justice Villon, with Justices De Guia-Salvador and Lazaro-Javier concurring), affirmed the RTC orders, holding Sections 66–70 inapplicable and that R.A. No. 8291 (the GSIS Act of 1997), particularly Section 41(w), authorized GSIS to file suit in the RTC. OWD’s motion for reconsideration before the CA was denied in a ...(Pro-only)
Issues:
- Did the RTC have subject-matter jurisdiction over GSIS’s collection suit, or should the dispute have been administratively settled under Sections 66–70, Chapter 14, Book IV of E.O. No. 292?
- Was GSIS authorized under R.A. No. 8291 to institute a civil action in the RTC to recover unremitted premium contributions, and did the monetary am...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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