G.R. No. 223018 - Salabe vs. Social Security Commission

From August 1978 to February 1979, Leonarda Jamago Salabe worked as a helper in Ana Macas’s carinderia at Jagna Public Market, Bohol, and was registered under SSS No. 06-0618084-5.
After separation, she continued as a voluntary member, paying 137 monthly contributions. Upon reaching age 60 in 1993, she applied for and received a monthly retirement pension of ₱1,362.75 until July 2001.

In July 2001, SSS-Tagbilaran City Branch unilaterally terminated her pension. By letter dated March 24, 2008, Branch Head Marino Talictic declared her SSS membership cancelled for allegedly lacking an employer-employee relationship with Ana Macas.
Petitioner filed a petition with the Social Security Commission (SSC) on March 31, 2008, seeking declaration of her bona fide membership and restoration of pension, supported by her own testimony and affidavits of witnesses.

SSC dismissed her petition on June 6, 2012 for lack of proof of employment and ordered refund of benefits; motion for reconsideration was denied on June 10, 2013.
Court of Appeals affirmed SSC rulings by Decision on December 1, 2014 and denied reconsideration on January 28, 2016, upholding cancellation for absence of employer-employee relationship and finding no due process violation.

Whether there was a valid employer-employee relationship between petitioner and Ana Macas to support SSS membership.
Whether SSS complied with due process in cancelling petitioner’s membership and pension.
Whether petitioner, having made 137 contributions and meeting age requirements, is entitled to retirement benefits under RA 1161 (as amended by PD 1636) and RA 8282.