Case Summary (G.R. No. 169136)
Applicable Law and Relevant Facts
This case is reviewed under the provisions of the 1987 Philippine Constitution, specifically concerning social security laws. Respondents filed a petition with the Social Security Commission (SSC) seeking social security coverage and payment of contributions to qualify for benefits related to Fermin's death. Respondents asserted that Fermin worked as a survey aide under Engr. Bienvenido Orense, who is identified as the geodetic engineer for Asiatic Development Corporation. Fermin was killed while working on a project associated with the corporation.
Argument and Position of the Petitioner
Asiatic Development Corporation contested its liability by arguing that no employer-employee relationship existed between it and Fermin Brogada. The Petitioner maintained that Fermin was an employee of Engr. Orense, and consequently, the corporation was not obligated to report him for social security coverage. This denial of liability was essential to the corporation's defense in the SSC proceedings and subsequently in the Court of Appeals.
SSC Findings and Rulings
The SSC issued a ruling in favor of the Respondents, concluding that Fermin Brogada was indeed an employee of Asiatic Development Corporation during the disputed period of July 1994 to November 14, 1996. Consequently, the SSC ordered the Petitioner to remit unpaid social security contributions, penalties for late payments, and damages resulting from the failure to report Fermin for social security coverage. The ruling mandated that the Social Security System disburse the death benefit to the Respondents as secondary beneficiaries in compliance with existing rules.
Court of Appeals Affirmation
The decision of the SSC was upheld by the Court of Appeals. The CA affirmed the lower court’s findings, reinforcing that the SSC's resolution was supported by substantial evidence and lacking compelling reasons for reversal. The CA's affirmation rested on established facts that the existence of an employer-employee relationship was sufficient to warrant coverage under the Social Security Law.
Legal Standards for Review and Petitioner's Claims
In the petition for review on certiorari under Rule 45, only questions of law may be addressed. The Supreme Court noted that the determination of the employer-employee relationship is typically a factual matter. In this case, the factual findings by the SSC concerning Fermin's employment status were adopted by the CA and, thus, afforded a degree of respect and finality in legal terms. The arguments posited by the Petitioner were essentially reiterations of those prev
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Case Background
- The case involves a petition for review on certiorari filed by Asiatic Development Corporation against the spouses Wellington and Flordeliza Brogada.
- The petition challenges the decisions of the Court of Appeals (CA) dated May 31, 2005, and the resolution dated July 28, 2005, which affirmed the September 24, 2003 resolution of the Social Security Commission (SSC) in SSC Case No. 6-14922-99.
- The respondents are the parents of Fermin B. Brogada, who was allegedly employed by the petitioner from July 1994 until his death on November 14, 1996.
Employment Status of Fermin B. Brogada
- Respondents filed a petition with the SSC for social security coverage and payment of contributions to obtain benefits following Fermin's death.
- They claimed that Fermin was employed as a survey aide under Engr. Bienvenido Orense, a geodetic engineer of the petitioner.
- Fermin was reportedly working on a project for one of the petitioner's clients when he was shot and killed.
- The petitioner disputed this claim, asserting that there was no employer-employee relationship between them and Fermin, arguing that he was an employee of Engr. Orense.