GR 172101; (November, 2007) (Digest)
G.R. No. 172101 November 23, 2007
Republic of the Philippines, represented by the Social Security Commission and Social Security System, vs. Asiapro Cooperative.
FACTS
Asiapro Cooperative, a multi-purpose cooperative, entered into service contracts with Stanfilco. Its owner-members performed services for Stanfilco. These members did not receive wages but a share in the service surplus, determined by Asiapro’s board. The members requested Stanfilco to facilitate their SSS registration as self-employed individuals, with contributions covering both employer and employee shares under the law.
The SSS, however, contended that Asiapro was a manpower contractor and the employer of these owner-members. It demanded Asiapro register as an employer and remit corresponding SSS contributions. Asiapro refused, arguing no employer-employee relationship existed as the members were the cooperative itself. The SSS filed a petition before the Social Security Commission (SSC) to compel registration and remittance. Asiapro moved to dismiss, challenging the SSC’s jurisdiction absent a prior finding of an employer-employee relationship.
ISSUE
Whether the Social Security Commission has jurisdiction over the petition to compel coverage despite a dispute regarding the existence of an employer-employee relationship.
RULING
Yes, the SSC has jurisdiction. The Court clarified that the SSC’s jurisdiction under the Social Security Law is not contingent on a prior, conclusive finding of an employer-employee relationship. The law grants the SSC original jurisdiction to settle disputes “arising under this Act with respect to coverage, benefits, contributions, and penalties thereon.” The question of whether a worker is a covered employee under the SSS law is inherently linked to the issue of coverage, which falls squarely within the SSC’s mandate.
The existence of an employer-employee relationship is a factual and legal issue that the SSC is competent to determine in the exercise of its quasi-judicial functions. To require a prior ruling from the National Labor Relations Commission (NLRC) or regular courts on this matter would undermine the SSC’s statutory authority and lead to multiplicity of suits. The SSC can receive evidence and rule on the relationship as a preliminary matter to resolve the coverage dispute. Therefore, the SSC correctly denied the motion to dismiss and assumed jurisdiction to hear and decide the case on its merits.