GR L 46058; (December, 1987) (Digest)
G.R. No. L-46058 December 14, 1987
SOCIAL SECURITY SYSTEM, petitioner, vs. COURT OF APPEALS and QUALITY TOBACCO CORPORATION, respondents.
FACTS
Quality Tobacco Corporation (QTC) entered into a contract with Romeo Carreon, designating him as a “VENDEE.” The contract stipulated that Carreon would purchase cigarettes from QTC on a cash basis and sell them within an assigned territory at prices set by QTC. QTC could loan him a delivery truck for exclusive use in this endeavor, with Carreon bearing most operating costs. The contract was terminable upon one week’s notice by either party. After QTC terminated the contract, Carreon filed a petition with the Social Security Commission, claiming he was an employee and should be covered under the Social Security Law. QTC contended he was an independent businessman. The Commission ruled in favor of an employer-employee relationship, but the Court of Appeals reversed this decision, applying the doctrine from the Mafinco vs. Ople case and dismissing Carreon’s petition.
ISSUE
Whether an employer-employee relationship existed between Romeo Carreon and Quality Tobacco Corporation, making Carreon subject to compulsory coverage under the Social Security Law.
RULING
Yes, an employer-employee relationship existed. The Supreme Court reversed the Court of Appeals and reinstated the Social Security Commission’s resolution. The Court emphasized the four-fold test for determining such a relationship, with the “control test” being the most significant. The contract’s terms and the actual implementation revealed QTC’s pervasive control over Carreon’s work. QTC assigned his sales territory, dictated the prices and brands he could sell, prescribed his customers, issued circulars and memoranda, required daily, weekly, and monthly sales reports, supervised him through sales coordinators, provided a company truck for exclusive use, and even subjected him to disciplinary grounding. These “undisputed facts” demonstrated that QTC controlled not merely the desired results but the means and methods of Carreon’s sales activities. The Court also noted that findings of administrative agencies like the Social Security Commission are generally accorded respect and finality. The contractual label of “VENDEE” did not negate the economic realities and the element of control establishing an employment relationship.