G.R. No. 114427 - Geagonia vs. Court of Appeals

Petitioner: San Beda College, a duly organized domestic corporation.
Respondent: Social Security System, a government agency created by Republic Act 1161, as amended.

On August 30, 1957, the lay faculty clubs of San Beda College and the University of Sto. Tomas filed a petition for declaratory relief in the Court of First Instance of Manila (Civil Case No. 33578) seeking a determination on the applicability of the Social Security Act provisions to their respective benefits.
On the same day, the court issued a writ of preliminary injunction enjoining the Social Security Commission, its representatives, and agents from compelling the integration of the private benefits plan of the San Beda College Lay Faculty Gratuity and Retirement Fund into the Social Security System.

The Commission sought reconsideration of the injunction-order; on being denied, it pursued certiorari in this Court questioning the propriety of the writ's issuance.
On May 30, 1962, this Court rendered a judgment in favor of the petitioning Commission, dissolving the writ and remanding the case for further proceedings.

Following the dissolution of the injunction, San Beda College paid the unremitted premiums amounting to P121,111.07 in installments on October 2, 1962 (P10,000.00), February 21, 1963 (P40,000.00), and June 7, 1961 (P71,111.07).
On November 2, 1964, the Court of First Instance of Manila dismissed Civil Case No. 33578 due to the petitioners’ lack of initiative to prosecute the case.

On August 13, 1964, and again on January 18, 1965, the Social Security System demanded by letter that San Beda College pay penalties for the late remittance of premiums covering the period from September 1957 to August 1962, amounting to P120,785.45.
Upon San Beda College’s refusal to comply with this demand, the System filed a petition with the Social Security Commission (Case No. 475).
On December 1, 1966, based on the agreed facts, the Commission issued a resolution sustaining the penalty claim and ordering San Beda College to pay the sum as penalties, with a stipulation for distraint and levy by a Sheriff in the event of nonpayment.

Imposes the obligation on employers to remit contributions and provides for a penalty of three percent per month for delayed remittance.
The legal framework discussed emphasizes that both the act of payment and collection are integral to the premium remittance process.

Grants the Commission jurisdiction over disputes related to premium contributions and penalties.
Provides for administrative adjudication and sets a fifteen-day period for decisions to become final unless appealed, subject to judicial review.

Reference to Social Security Commission vs. Bayona and Jao vs. Royal Financing Corp. for related issues on injunctions and damages.
Emphasis on the requirement that any damages or penalties accruing due to an injunction should have been ascertained and addressed as part of the remedy secured by the party who obtained the injunction.

Whether San Beda College is liable to pay penalties for the delayed remittance of premium contributions for the period from September 1957 to August 1962.

Whether the issuance and existence of the preliminary injunction, which prevented the Social Security System from properly demanding remittance, suspended the employer’s obligation to pay contributions and, by extension, the imposition of penalties.

Whether the Social Security Commission had the requisite jurisdiction under the Social Security Act and its amendments to impose penalties on San Beda College.

Whether Section 22’s imposition of penalties remains applicable given the procedural and factual developments, including subsequent payments and administrative rulings.