GR L 22569; (October, 1974) (Digest)
G.R. No. L-22569 October 15, 1974
FELICISIMO ENORME, plaintiff-appellant, vs. SOCIAL SECURITY SYSTEM, defendant-appellee.
FACTS
Plaintiff Felicisimo Enorme filed a complaint in the Municipal Court of Gubat, Sorsogon, seeking a refund of P237.60 representing his Social Security contributions upon separation from employment, plus damages and attorney’s fees totaling P4,500.00. The municipal court dismissed the complaint on jurisdictional grounds. Enorme appealed to the Court of First Instance of Sorsogon.
The factual backdrop reveals that the Social Security System (SSS) had previously sent a refund of P107.15 to Enorme’s Manila address, but it was returned unclaimed due to his change of residence without notice to the SSS. Crucially, before the appeal reached the Court of First Instance, Enorme’s counsel acknowledged receipt of the P107.15 refund in a letter dated August 26, 1963, albeit under protest, objecting that the amount should have been higher to include his employer’s contributions.
ISSUE
Whether the municipal court and the Court of First Instance had jurisdiction over Enorme’s claim for refund and damages against the Social Security System.
RULING
The Supreme Court affirmed the order of dismissal, holding that the lower courts lacked jurisdiction. The legal logic is anchored on the doctrine of exhaustion of administrative remedies and the specific appellate procedure mandated by the Social Security Act ( Republic Act No. 1161 ).
The law explicitly vests the Social Security Commission with the exclusive quasi-judicial power to adjudicate and settle all disputed claims under the Act. Section 5 of the Act provides that a decision of the Commission may be reviewed by the Court of Appeals on questions of law and fact, or by the Supreme Court on pure questions of law. This statutory scheme deliberately bypasses the Court of First Instance and municipal courts. The requirement to first exhaust this administrative remedy is a condition precedent to judicial action and is not a denial of access to courts.
The Court rejected Enorme’s attempt to circumvent this procedure by framing his action as one for damages arising from the SSS’s alleged negligence. The acknowledgment of receipt of the P107.15 refund, even if under protest, confirmed that the core of the dispute was a claim for underpayment of a statutory benefit—a matter squarely within the Commission’s exclusive jurisdiction. The alleged negligence in sending the refund to a wrong address was deemed immaterial once the refund was admitted to have been received. Consequently, the municipal court and the Court of First Instance were correct in dismissing the case for lack of jurisdiction over the subject matter.