Case Digest (G.R. No. 192571) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines v. Asiapro Cooperative (G.R. No. 172101, November 23, 2007), the Social Security System (SSS) through the Social Security Commission (SSC) filed a petition-complaint on June 12, 2003 against Asiapro Cooperative, a multi-purpose cooperative registered under R.A. No. 6938 on November 23, 1999, for failure to register as employer and remit contributions for its owners-members assigned to Stanfilco under various service contracts. Asiapro’s owners-members received service surplus rather than wages and had themselves registered as self-employed with the SSS. On September 26, 2002, SSC’s Mindanao Division Vice-President notified Asiapro that it was a manpower contractor and an employer under the Social Security Act of 1997 (R.A. No. 8282). Asiapro denied any employer-employee relationship and ignored subsequent SSC demands dated October 9 and October 21, 2002. SSC denied Asiapro’s Motion to Dismiss on February 17, 2004 and again on September 16, 2004. As Case Digest (G.R. No. 192571) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Legal Basis
- Petitioner Republic of the Philippines is represented by the Social Security Commission (SSC) and the Social Security System (SSS), bodies created under Republic Act No. 1161, as amended by R.A. 8282 (Social Security Act of 1997).
- Respondent Asiapro Cooperative is a multi-purpose cooperative organized under R.A. 6938 (Cooperative Code of the Philippines) and registered with the Cooperative Development Authority on 23 November 1999.
- Cooperative Structure and Operations
- Asiapro’s by-laws classify members as (a) regular members (full rights) and (b) associate members (no voting rights).
- It entered into Service Contracts with Stanfilco–DOLE Philippines, Inc.; members render services and receive shares in the service surplus instead of traditional wages.
- SSC Proceedings
- In September–October 2002, SSS letters instructed Asiapro to register as an employer and report its owner-members as employees for compulsory SSS coverage; Asiapro refused.
- On 12 June 2003, SSS filed a petition-complaint with the SSC seeking to compel Asiapro (or alternatively Stanfilco) to register as employer, report its members, and remit contributions.
- Asiapro filed an Answer with Motion to Dismiss, arguing lack of an employer-employee relationship; the SSC denied the motion on 17 February 2004 and again on 16 September 2004.
- Court of Appeals Proceedings
- Asiapro elevated the SSC orders via a Petition for Certiorari (CA-G.R. SP No. 87236), contending SSC lacked jurisdiction and that the NLRC should resolve the employment relationship question.
- On 5 January 2006, the Court of Appeals granted the petition, annulled the SSC orders, and dismissed the SSS petition; its denial of reconsideration was issued on 20 March 2006.
- Supreme Court Petition
- SSS and SSC filed a Petition for Review on Certiorari under Rule 45, challenging the CA’s ruling on SSC jurisdiction and Asiapro’s estoppel.
- The parties submitted memoranda debating: SSC’s jurisdiction under R.A. 8282; estoppel by Asiapro; and whether an employer-employee relationship exists.
Issues:
- Jurisdiction
- Does the SSC have jurisdiction over the SSS petition-complaint concerning the compulsory coverage of Asiapro’s owner-members?
- Estoppel
- Is Asiapro estopped from questioning SSC’s jurisdiction after filing an Answer with Motion to Dismiss before the SSC?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)