GR 169136; (July, 2006) (Digest)
G.R. No. 169136 , July 14, 2006
ASIATIC DEVELOPMENT CORPORATION, petitioner, vs. SPOUSES WELLINGTON and FLORDELIZA BROGADA, respondents.
FACTS
Respondents, the parents of the late Fermin B. Brogada, filed a petition with the Social Security Commission (SSC) seeking social security coverage and payment of contributions to claim death benefits. They alleged that Fermin was employed as a survey aide by petitioner Asiatic Development Corporation from July 1994 until his death on November 14, 1996, while working on a project under the supervision of the company’s geodetic engineer, Engr. Bienvenido Orense. Petitioner denied liability, contending that no employer-employee relationship existed as Fermin was allegedly solely an employee of Engr. Orense and not of the corporation, thus absolving it from any obligation to report him for SSS coverage.
The SSC ruled in favor of the respondents, declaring Fermin as a compulsory employee of the petitioner for the relevant period. It ordered the corporation to pay unpaid SSS contributions, penalties, and damages for failure to report. The Court of Appeals affirmed the SSC’s resolution in toto. Petitioner now elevates the case to the Supreme Court via a petition for review on certiorari, reiterating its argument that Fermin was not its employee.
ISSUE
Whether the Supreme Court can review the factual finding of the existence of an employer-employee relationship between petitioner and the deceased Fermin Brogada.
RULING
The petition is denied. The Supreme Court upheld the rulings of the SSC and the Court of Appeals. The core issue of the existence of an employer-employee relationship is fundamentally a question of fact. In a Rule 45 petition, the Court’s jurisdiction is limited to reviewing questions of law, not re-examining factual determinations. Factual findings of quasi-judicial agencies like the SSC, when affirmed by the Court of Appeals and supported by substantial evidence, are accorded finality and respect.
The Court found no compelling reason to deviate from this doctrine. Petitioner’s arguments merely rehashed its unsuccessful positions below and did not fall within any recognized exception warranting a factual review, such as a lack of evidentiary support or a grave abuse of discretion. Consequently, the factual conclusion that Fermin was petitioner’s employee stands, making the corporation liable for the unpaid SSS contributions and related penalties as ordered.