GR 238104; (February, 2019) (Digest)
G.R. No. 238104 . February 27, 2019.
ODELON ALVAREZ MIRANDA, PETITIONER, VS. SOCIAL SECURITY COMMISSION AND SOCIAL SECURITY SYSTEM, REPRESENTED BY CARINA L. CATAHAN, RESPONDENTS.
FACTS
The Social Security System (SSS) filed a petition before the Social Security Commission (SSC) against Onise Marketing and its owner/manager, Odelon Alvarez Miranda, for the collection of unpaid SSS contributions and penalties. The SSC declared them in default for failure to file an answer. In 2013, the SSC issued a Resolution finding them liable and ordering payment. Miranda later filed an Urgent Motion to Annul the 2013 Resolution and to Quash the subsequent Writ of Execution, arguing the SSC never acquired jurisdiction over his person as he did not receive any summons or processes. The SSC denied his motion, ruling that summons was personally served on him in 2006 and that his partial payments constituted a tacit admission of liability and voluntary submission to its jurisdiction.
ISSUE
Whether the Social Security Commission acquired jurisdiction over the person of petitioner Odelon Alvarez Miranda.
RULING
Yes, the SSC acquired jurisdiction over Miranda. The Supreme Court affirmed the findings of the SSC and the Court of Appeals, with modification. Jurisdiction over the person is acquired either by voluntary appearance or through coercive process. The SSC’s records established that the summons and a copy of the petition were personally served upon and received by Miranda on August 7, 2006. This valid service vested the SSC with jurisdiction. Furthermore, Miranda’s subsequent actions constituted voluntary appearance, which also confers jurisdiction. His partial payments towards the delinquent contributions, made even after the order of default, and his availment of the benefits of condonation under the law, are clear acts of acknowledgment of the SSC’s authority and of his liability. These acts effectively cured any alleged defect in the service of subsequent orders. The principle is that a party who invokes the jurisdiction of a court or tribunal for a specific relief is deemed to have submitted to its authority. By seeking the benefit of condonation through payment, Miranda voluntarily submitted to the SSC’s jurisdiction. Therefore, his belated challenge to jurisdiction, filed only after a writ of execution was issued, is without merit.