G.R. No. 46192 August 29, 1989
SOCIAL SECURITY SYSTEM, petitioner, vs. COURT OF APPEALS and MANUEL G. RAMOS, respondent.

FACTS

Felicisima Orcino filed a petition with the Social Security System (SSS) against architect Manuel G. Ramos, seeking payment of death benefits for her deceased son, Emeterio Orcino. She alleged that Ramos, as her son’s employer, failed to register him with the SSS, thereby precluding her from receiving statutory benefits. Orcino claimed Emeterio worked for Ramos as a laborer and later as a foreman. She had previously received sums totaling P7,792.00 from Ramos and a client, Ms. de Jesus, accompanied by quitclaims dismissing claims under the Workmen’s Compensation Act and the Social Security Act.
Ramos denied being an employer, asserting his role was strictly limited to architectural supervision and administration for clients. He contended that Emeterio was never his employee but was hired by the project owners, such as Ms. de Jesus, who paid the wages. The SSS intervened, presenting records showing Ramos had registered as an employer but had not listed Emeterio or submitted required monthly contribution forms for relevant periods. The SSS ruled against Ramos, holding him liable for death benefits and back contributions, minus the P3,600.00 already paid.

ISSUE

Whether the Court of Appeals erred in reversing the SSS decision by finding that no employer-employee relationship existed between Manuel G. Ramos and the deceased Emeterio Orcino.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The Court emphasized that it is not a trier of facts and generally does not review factual determinations of the Court of Appeals, as petitions for review on certiorari must raise only questions of law. The SSS sought a reversal of the appellate court’s factual conclusion regarding the absence of an employer-employee link, which falls outside the scope of a certiorari proceeding absent any showing that the findings are grounded on speculation or are unsupported by evidence.
The legal logic rests on the principle of finality of factual findings. The Court of Appeals meticulously evaluated the evidence, deeming Orcino’s testimony inadequate and partly hearsay, and found Ramos’s evidence credible in establishing that he acted solely as an architect without employing workers directly. The quitclaim documents signed only by Orcino were correctly deemed not admissions by Ramos, and the payments were characterized as charitable rather than based on a recognition of legal obligation. Consequently, without a proven employer-employee relationship, no duty to register the worker with the SSS arose, and thus no liability for benefits under the Social Security Act could be imposed on Ramos. The petition, being essentially a plea to re-examine facts, was properly dismissed.