Case Digest (G.R. No. L-16704) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Victorias Milling Company, Inc. v. Social Security Commission (114 Phil. 555), decided March 17, 1962 under the 1935 Constitution, the Social Security Commission (SSC) on October 15, 1958 promulgated Circular No. 22, instructing that “all bonuses and overtime pay, as well as the cash value of other media of remuneration” be included in the employee’s compensation for computing Social Security premiums up to P500 per month. Petitioner–appellant Victorias Milling Company, Inc. protested, citing Circular No. 7 (October 7, 1957), which expressly excluded bonuses and overtime from premiums, and challenged SSC’s authority to issue Circular No. 22 without Presidential approval or publication in the Official Gazette. The Commission ruled that the directive was a mere administrative interpretation of Republic Act No. 1161, as amended by Republic Act No. 1792, and not a rule or regulation requiring presidential sanction or Gazette publication. Victorias Milling then elevated t... Case Digest (G.R. No. L-16704) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Issuance and content of Circular No. 22
- On October 15, 1958, the Social Security Commission promulgated Circular No. 22, effective November 1, 1958, directing all employers to include bonuses, overtime pay, and the cash value of other remuneration in computing employee “compensation” for Social Security premium contributions, subject to a P500 monthly cap.
- The petitioner, Victorias Milling Company, Inc., protested that Circular No. 22 conflicted with earlier Circular No. 7 (October 7, 1957), which expressly excluded bonuses and overtime pay, and challenged the Commission’s authority to issue the circular without presidential approval or publication in the Official Gazette.
- Administrative ruling and appeal
- The Social Security Commission overruled petitioner’s objections, characterizing Circular No. 22 as an administrative interpretation or policy statement, not a rule or regulation requiring presidential approval or Gazette publication.
- Dissatisfied, petitioner appealed to the Supreme Court, raising the question of whether Circular No. 22 is a “rule or regulation” under Section 4(a) of Republic Act No. 1161, as amended by Republic Act No. 1792, thereby necessitating presidential approval and Official Gazette publication.
Issues:
- Whether Circular No. 22 is a “rule or regulation” under Section 4(a) of Republic Act No. 1161, requiring presidential approval and publication in the Official Gazette.
- Whether the Commission’s interpretation in Circular No. 22 correctly reflects the amended statutory definition of “compensation” under Republic Act No. 1792.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)