G.R. No. 165482 - Social Security Commission vs. Alba

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G.R. No. 165482: Social Security Commission vs. Alba

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Title Source: Supreme Court: Social Security Commission vs. Alba

Case: G.R. No. 165482

Decision Date: Jul 23, 2008

Apolonio Lamboso sought SSS retirement benefits, denied due to insufficient contributions. Supreme Court ruled Far Alba, as his employer, liable for delinquent contributions from 1960-1970, reversing lower court decisions.

Case Digest (G.R. No. 165482)
Expanded Legal Reasoning Model

Facts:

Background of the Claim and Denial

In 1991, Apolonio Lamboso filed a claim for his retirement benefit before the Social Security System (SSS).
His claim was denied on the ground that he had only 39 paid contributions, which under Republic Act (R.A.) No. 1161 (the Social Security Act of 1954) was insufficient to qualify for a monthly pension.

Alleged Employment and Subsequent Proceedings

Lamboso alleged he was employed in various capacities:

At Hda. La Roca (from 1960 to 1973) as a “cabo” working for respondent Far Alba.
At Hda. Alibasao (from 1973 to 1979) and Hda. Kamandag (from 1979 to 1984) working for employer Ramon S. Benedicto.

Upon filing his claim, Lamboso also sought:

An adjustment of the date of his Social Security (SS) coverage.
The remittance of his delinquent monthly contributions.

The Social Security Commission (SSC) rendered a resolution on 28 November 2001 ordering:

Respondent Far Alba to remit delinquent contributions for the period 1960 to April 1973 along with penalties and damages.
Respondent Ramon Benedicto to remit contributions for the period May 1973 to 1984 with the corresponding penalties and damages.

The SSC’s order further directed the SSS to pay Lamboso his retirement benefit upon the filing of the claim.

Filing and Denial of Responsive Pleadings

Respondent Far Alba was declared in default on November 14, 1997 for failure to file his responsive pleading.
Far Alba later pursued a motion for reconsideration on 26 June 2002, arguing:

Lack of notice and denial of due process.
That he was not obligated to remit contributions for periods outside the employer-employee relationship.

The Commission denied his motion, emphasizing that:

The summons was duly served.
The default was proper after the reglementary period expired without a responsive pleading.

Court of Appeals (CA) Ruling and Subsequent Petition

Far Alba filed a Petition for Review under Rule 43 before the Court of Appeals challenging:

Violation of his constitutional rights to due process and equal protection.
That his contribution remittance obligations did not extend to periods without a bona fide employer-employee relationship.
That Lamboso’s claim was time-barred by prescription.

The CA reversed the SSC’s decision by holding that:

Far Alba could not be considered Lamboso’s employer prior to 1970 under Section 8(c) of the Social Security Act of 1954.
Since Far Alba had already remitted the 39 contributions for January 1970 to March 1973, he should be absolved from the liability.
Claims for remittance of contributions before 1970 should have been filed against the estate proceedings of Arturo Alba, Sr.

Evidence and Testimony Regarding the Employer-Employee Relationship

Lamboso’s own testimony and corroboration by co-workers established that:

Far Alba served as the hacienda’s administrator from 1960 to 1965 and continued managing it beyond that period.
Far Alba was directly involved in the remuneration of Lamboso and exercised control over his employment.

Testimonies from witnesses (including Rodolfo Sales) confirmed:

The existence of an employer-employee relationship through the payment of wages and deductions for SSS premiums.
The supervisory and managerial role of Far Alba in administering the hacienda, thereby influencing Lamboso’s engagement.

Contentions Raised in the Petition for Review

The SSC contended that under the Social Security Act of 1954:

The term “employer” should be broadly interpreted to include those acting in an administrative capacity with substantial control.
Far Alba, being the administrator and son of the owner, performed functions that equated him with an employer.

Far Alba maintained:

That he was not Lamboso’s employer prior to 1970.
That he was not the hacienda’s administrator at the time due to his absence while studying law.
That his contributions were, in fact, duly remitted for the period covered under his role from January 1970 onward.

Issues:

Determination of Employer-Employee Relationship

Whether Far Alba, acting as the administrator of the hacienda and a member of the owner’s family, can be considered an “employer” under Section 8(c) of the Social Security Act of 1954 prior to 1970.
Whether the control test — encompassing selection, wage payment, dismissal power, and control over work methods — establishes an employer-employee relationship in this case.

Due Process and Procedural Concerns

Whether Far Alba was deprived of due process by the manner and timing of the service of summons and his subsequent declaration in default.
Whether his claim of lack of notice merits the reversal of the Commission’s resolution.

Alleged Prescriptive Bar and Filing Against Estate Proceedings

Whether Lamboso’s claim for the remittance of SS contributions was barred by prescription.
Whether the nature of the claim (akin to a tax claim) precludes it from being filed against the estate proceedings of a deceased employer (Arturo Alba, Sr.).

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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END