Case Summary (G.R. No. 210500)
Petitioners, Respondents and Key Dates
• April 19, 2013 – SSC Resolution No. 262-s approving hike (10.4% to 11%; MSC ₱15,000 to ₱16,000), subject to presidential approval.
• September 20, 2013 – SSC Resolution No. 711-s confirming the hike.
• October 2, 2013 – SSS Circular 2013-010 prescribing new employer/employee share (7.37%/3.63%).
• January 10, 2014 – Filing of Petition for certiorari and prohibition.
• April 2, 2019 – En banc decision.
Applicable Law
• 1987 Philippine Constitution, Article VIII (Judicial Power, expanded certiorari jurisdiction).
• Republic Act No. 8282 (Social Security Act), especially Sections 3 (“Commission composition”), 4 (“Powers and duties”), 5 (“Settlement of disputes; exhaustion of administrative remedies”), 18 (“Rate-setting delegation”).
• Rule 65, Rules of Court (certiorari and prohibition).
Issues Presented
- Proper exercise of judicial review under the 1987 Constitution.
- Existence of an actual case or controversy.
- Applicability of the exhaustion doctrine and primary administrative jurisdiction.
- Petitioners’ legal standing.
- Merits: (a) Validity of the delegation in RA 8282; (b) Reasonableness and lawfulness of the contribution increase; (c) Validity of the employer-employee ratio adjustment.
Judicial Review and Justiciability
The Court reaffirmed its expanded certiorari power under Art. VIII, Sec. 1 to correct grave abuse of discretion by any branch. An actual, concrete controversy and legally demandable right are prerequisites. Petitioners alleged constitutional rights to worker welfare and social justice but failed to demonstrate a direct enforceable right to fixed contribution levels. The issues—though affecting millions—were nonetheless heard under the mootness exception for matters of grave constitutional importance, public interest, controlling guidance needs, and potential repetition yet evading review.
Exhaustion of Administrative Remedies and Primary Jurisdiction
Sections 4–5 of RA 8282 confer exclusive jurisdiction on the SSC over disputes on coverage, benefits, contributions, and penalties, and require administrative appeal and motion for reconsideration before court recourse. Petitioners did not file any SSC protest or request reconsideration. Their Rule 65 petition was premature and violated both the exhaustion doctrine and the doctrine of primary administrative jurisdiction.
Standing to Sue
Individual members (Ustarez, Carranza, Gonzaga, Maniquiz, Alcantara, Hicap) showed direct, material injury and had standing. Organizational petitioners were permitted under the “transcendental importance” doctrine given the widespread impact on SSS members and the lack of other challengers.
Validity of Legislative Delegation
RA 8282 fully prescribes contribution rate and MSC schedules, then delegates to the SSC, “taking into consideration actuarial calculations and rate of benefits,” with presidential approval. The statute is complete and contains sufficient standards (“actuarial calculations” and “rate of benefits”) to guide and limit the SSC. Delegation to specialized agencies for complex technical matters is constitutionally permissible.
Lawful Exercise of De
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Facts of the Case
- On April 19, 2013, the Social Security Commission (SSC) issued Resolution No. 262-s. 2013 raising the SSS member contribution rate from 10.4% to 11% and the maximum monthly salary credit from ₱15,000 to ₱16,000, subject to Presidential approval.
- On September 6, 2013, the President approved the proposed increases.
- On September 20, 2013, the SSC adopted Resolution No. 711-s. 2013 confirming the rate and salary-credit adjustments.
- On October 2, 2013, SSS President and CEO De Quiros issued Circular No. 2013-010, prescribing the revised contribution schedule effective January 2014, sharing the 0.6% hike equally between employer (7.37%) and employee (3.63%).
- On January 10, 2014, petitioners (Kilusang Mayo Uno, labor and party-list representatives, related NGOs, and individual SSS members) filed a Petition for Certiorari and Prohibition questioning the validity of these issuances.
Petitioners’ Contentions
- Majority are SSS members directly harmed by the premium hike, asserting locus standi; other petitioners claim transcendental importance of raised issues.
- Alleged unlawful delegation under Section 18, R.A. 8282—standards (“actuarial calculations” and “rate of benefits”) deemed vague, lacking adequate guidelines or boundaries.
- Claimed violation of Section 4(b)(2), R.A. 8282, which prohibits benefit increases requiring higher contribution rates.
- Argued the hike is an invalid exercise of police power—allegedly neither reasonably necessary nor just, and unduly oppressive to labor.
- Contended that changing the employer-employee contribution ratio from 70:30 to 50:50 is grossly unjust and beyond SSC’s power.
- Invoked constitutional mandates to protect workers’ rights and promote social justice.
- Sought a temporary restraining order or preliminary injunction to halt implementation.
Legal Issues Presented
- Can the Supreme Court exercise its judicial-review power over these executive issuances?
- Is there an actual case or controversy ripe for adjudication?
- Does