Case Digest (G.R. No. 32652)
Facts:
The Salvation Army, an international evangelical Christian church and social welfare organization incorporated in the Philippines as a non-stock, non-profit religious entity with headquarters in Malate, Manila, registered with the Social Security System (SSS) on March 22, 1962, listing its officers as “employees.” In December 2005, the petitioner filed a request to convert the membership status of its officers from employee to voluntary member, which the SSS denied in January 2006 for lack of legal and factual basis and again denied on reconsideration in March 2006. The petitioner elevated the matter to the Social Security Commission (SSC), which in November 2013 affirmed the denial of conversion, a resolution whose reconsideration was likewise denied. Thereafter, the petitioner sought relief from the Court of Appeals (CA) via a petition under Rule 43, but on September 30, 2016, the CA dismissed the petition and affirmed the SSC’s findings that an employer-employee relationshipCase Digest (G.R. No. 32652)
Facts:
- Organizational and registration background
- The Salvation Army is a non-stock, non-profit religious organization incorporated in the Philippines, using military terminology, with headquarters in Manila.
- On March 22, 1962, it registered with the Social Security System (SSS) as employer No. 03-2070300-3, listing its officers as “employees.”
- Administrative and judicial course
- On December 19, 2005, petitioner requested conversion of its officers’ SSS membership from “employees” to “voluntary/self-employed.” The SSS denied the request on January 30, 2006 and its motion for reconsideration on March 13, 2006.
- Petitioner elevated to the Social Security Commission (SSC), which affirmed on November 6, 2013 and denied reconsideration on March 27, 2014.
- Under Rule 43, petitioner sought CA review; on September 30, 2016 the CA dismissed the petition and affirmed the SSC. Reconsideration was denied February 21, 2017.
- Petitioner filed a Rule 45 petition with the Supreme Court, contesting classification of its officers as employees and invoking free-exercise and church-state separation grounds.
Issues:
- Classification
- Are petitioner’s religious ministers/officers “employees” under the Social Security Law?
- Constitutional limits
- Does requiring SSS coverage of the ministers infringe upon the constitutional right to free exercise of religion or violate church-state separation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)