Case Summary (G.R. No. 181154)
Background of Employment and Contributions
Haveria was employed by the SSS from May 1958 until July 1984 and served as an officer/treasurer of the SSS Employees' Association (SSSEA). He had 281 monthly contributions, reaching retirement age on August 8, 1997. Following his retirement, he received monthly pension benefits until June 2002, when the SSS suspended his benefits based on a legal opinion regarding similar claims from two other SSSEA officers.
Suspension of Benefits
In June 2002, Haveria received notice from the SSS regarding the suspension of his pension benefits. This decision referenced two other former SSS employees whose claims were denied due to the lack of an employer-employee relationship with the SSSEA. Consequently, Haveria petitioned the Social Security Commission (SSC) to declare his SSS membership valid and restore his pension, asserting that his contributions were legitimate under his role within the SSSEA.
SSC Resolution Findings
The SSC's Resolution on December 7, 2005, held that Haveria's membership was erroneous since he was never an employee of the SSSEA but of the SSS, thereby insufficient to justify compulsory coverage. Although Haveria made a total of 281 contributions, the SSC determined that valid coverage only began in July 1989, leading to a credit of only 93 contributions as they ordered the contributions from the SSSEA to be treated as voluntary after April 1997. They also mandated that any advanced pension payments made should be offset against future pensions.
Court of Appeals Decision
The Court of Appeals affirmed the SSC's Resolution, maintaining that Haveria was not an SSSEA employee and reiterating the absence of any employment relationship. The appellate court further upheld the principle that estoppel does not apply against the government, emphasizing administrative agencies' findings should be respected unless there's proof of grave abuse of discretion or error of law.
Petitioner's Arguments
Haveria continued to contest the CA's ruling, arguing his status as a member of the SSSEA permitted him valid SSS membership and that government employees could simultaneously engage in private employment. He maintained there is no law prohibiting this and that membership can exist without a formal employer-employee relationship.
SSS's Position
The SSS, represented by the Office of the Solicitor General, argued that Haveria's registration was flawed due to the absence of an employment relationship with the SSSEA. They cited that labor organizations are excluded from the definition of an employer, thus negating Haveria's claims to compulsory membership. The SSS also reiterated that the principle of estoppel is inapplicable to government mistakes.
Court's Ruling
The Supreme Court ruled in favor of the enforcement of the SSC and CA decisions, citing that Haveria’s inclusion as a compulsory
...continue readingCase Syllabus (G.R. No. 181154)
Background of the Case
- The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court, filed by Ramchrisen H. Haveria against the Social Security System (SSS), Corazon de la Paz (President and CEO of SSS), and Leonora S. Nuque (officer-in-charge of Social Security Services).
- The petition assails the Decision of the Court of Appeals (CA) dated October 22, 2007, and the Resolution dated January 14, 2008, which affirmed the Resolution and Order of the Social Security Commission (SSC) in SSC Case No. 4-15695-04.
Facts of the Case
- Haveria was employed by SSS from May 1958 to July 1984 and served as an officer/treasurer of the SSS Employees’ Association (SSSEA), which remitted his contributions from May 1966 to December 1981.
- After leaving SSS, he worked for private entities until reaching retirement age on August 8, 1997.
- Haveria received retirement benefits from August 1997 until July 2002, but in June 2002, he was notified of the suspension of his retirement benefits due to a legal opinion related to another claim involving former SSS employees Ledesma and Pahuyo.
- Haveria petitioned the SSC for the declaration of his SSS membership's validity and the restoration of his pension, arguing his contributions were valid due to his employment with SSSEA.
The SSC Resolution
- On December 7, 2005, the SSC determined that Haveria’s SSS coverage was erroneous because he was not an employee of SSSEA, but of SSS, affirming that labor unions are not considered employers of their officers or members.
- The SSC concluded that while Haveria had made a to