Case Summary (G.R. No. 165482)
Antecedents of the Case
In 1991, Apolonio Lamboso filed a claim for retirement benefits with the SSS, which was denied due to insufficient contributions—only thirty-nine paid contributions were recorded under Republic Act (R.A.) No. 1161, governing the Social Security System. Lamboso appealed this denial in December 1996, asserting that he was entitled to a monthly retirement pension due to his alleged employment history and his claim for the adjustment of his Social Security coverage period.
Social Security Commission's Resolution
On November 28, 2001, the Social Security Commission (the Commission) ruled in favor of Lamboso, ordering Far Alba to remit the delinquent contributions owed to the SSS from 1960 to April 1973 based on his salaries during that period. Additionally, the Commission ordered Ramon Benedicto to remit contributions for Lamboso's employment from 1973 to 1984. The Commission’s decision emphasized the lack of a timely rebuttal from Far Alba due to his default status.
Respondents' Opposition and Appeals
Subsequently, Far Alba filed a motion for reconsideration, claiming a lack of notice and denial of due process, which the Commission denied. Far Alba then challenged the Commission’s ruling in the Court of Appeals, contending that he had no obligation to remit contributions prior to 1970 because he was merely an administrator of the hacienda and not an employer as defined under the Social Security Act. Furthermore, he argued that Lamboso's claim had already prescribed.
Court of Appeals' Decision and Rationale
The Court of Appeals ultimately reversed the Commission’s decision, holding that Far Alba was not considered Lamboso’s employer before 1970. The Court concluded that, as the administrator of a family-owned hacienda, Far Alba did not meet the definition of an employer who is engaged in a trade or business under the relevant provisions of the Social Security Act. The Court also directed that claims for contributions prior to 1970 should have been filed against the estate of Arturo Alba, Sr., Far Alba's deceased father.
Supreme Court's Review and Findings
In granting the petition from the Social Security Commission, the Supreme Court reviewed the definition of an employer under the Social Security Act of 1954, exploring whether Far Alba, being the administrator, could be considered an employer. The Court found that he had effectively served as Lamboso's employer or was at least involved in the management of the hacienda in a capacity that established an employer-employee relationship.
Employment Relationship and Contributions Liability
The analysis pivoted on the control test to establish an employer-employee relationship, determining that Lamboso was indeed hired and compensated directly by Far Alba. The Court determined that the familial connection and the role of an administrator involved sufficient responsibility for remitting contributions to the SSS.
Leg
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Case Overview
- This case involves a Petition for Review on Certiorari by petitioners Social Security Commission and Apolonio Lamboso against respondent Far S. Alba.
- The petition challenges the Court of Appeals' Decision dated July 20, 2004, and its Resolution dated September 30, 2004, which reversed a prior resolution from the Social Security Commission (SSC).
- The origins of the case date back to a claim filed by Apolonio Lamboso in 1991 for retirement benefits from the Social Security System (SSS), which was denied due to insufficient paid contributions.
Background of the Case
- Apolonio Lamboso filed a claim for retirement benefits in 1991, which was denied as he had only 39 paid contributions under Republic Act No. 1161 (the Social Security Act of 1954).
- Lamboso appealed this denial to the SSC on December 11, 1996, seeking recognition of his employment and requesting adjustments to his SSS coverage dates and payment of delinquent contributions.
- The SSC found that Lamboso worked for various employers, including Hda. La Roca owned by Far Alba, and established the existence of unpaid contributions that needed to be remitted to the SSS.
Findings of the Social Security Commission
- The SSC determined that Far Alba had failed to submit required contributions for Lamboso from 1960 to 1973.
- The Commission ordered Far Alba to pay Lamboso's delinquent contributions, along with penalties and damages, while also mandating the SSS to process Lamboso's retirement benefit claims.
- Far Alba was declared in default for failing to