Title
Santiago vs. Court of Appeals
Case
G.R. No. L-39949
Decision Date
Oct 31, 1984
Employees sought credit for unremitted SSS contributions and salary loan payments deducted by employer; SC ruled contributions credited, but loan payments not, as employer not SSS agent.

Case Digest (G.R. No. L-39949)

Facts:

Manuel H. Santiago, et al. v. Court of Appeals and the Social Security System, G.R. No. L-39949, October 31, 1984, First Division, Melencio‑Herrera, J., writing for the Court.

Petitioners were long‑time employees of I‑Feng Enamelling Company (Phil.) Inc., some from 1950 until the company closed on May 1, 1965. After the enactment of the Social Security Act, Republic Act No. 1161, petitioners' salaries were subject to deductions for their SSS premium contributions and for installments on salary loans they had obtained from the Social Security System. Those sums were withheld by the employer but, according to the uncontroverted factual findings adopted by the Court of Appeals, the employer failed to remit to the System the salary loan installments (P7,940.13) and unpaid back premiums (P137,187.90 as of July 1966), plus penalties (P63,734.97 as of August 9, 1966) (Exhibit B).

Petitioners asked the Social Security Commission to have those withheld amounts credited to their individual SSS accounts. The Commission denied the petition, reasoning that if deductions were made but not remitted the petitioners should proceed against their employer; the Commission nonetheless directed the System to study what action to take to protect its interests. Petitioners appealed to the then Court of Appeals, which, in a decision promulgated December 23, 1974, affirmed the Commissio...(Subscriber-Only)

Issues:

  • Whether salary loan installments withheld by the employer but not remitted to the System should be credited to the employees on the ground that the employer was the System’s agent for collection.
  • Whether premium contributions withheld by the employer but not remitted to the System should be cre...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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