Lopez-Jison v. Social Security Commission
REITERATIONFacts
1. The Antecedents: Private respondent Felipe Diacamos, an employee of Hacienda Doña Lilia owned by petitioner Lilia Lopez-Jison, filed a complaint with the Social Security Commission. Diacamos sought payment for alleged unpaid premium contributions, penalties, and damages, equivalent to the retirement benefits he would have received from the Social Security System (SSS) had he been reported for coverage on time. The Commission ruled in favor of Diacamos, holding Lopez-Jison liable for contributions, penalties for late payment, and damages equivalent to the retirement benefits. 2. Procedural History: Following the Social Security Commission's decision on June 20, 1984, Lopez-Jison's liability was computed at P11,416.98, plus additional contributions and penalties. To prevent the sale of her properties, Lopez-Jison paid P2,504.60 in contribution liabilities and P11,416.98 in penalties as of December 26, 1984. A further demand for P373.72 for penalties accrued after the initial payment was made. Lopez-Jison filed a Petition for Relief from Judgment with the Commission, which was denied, leading to the present petition. 3. The Petition: This case is before the Supreme Court on a Petition for Prohibition. Petitioner Lilia Lopez-Jison seeks to permanently prohibit the Social Security Commission and Felipe Diacamos from enforcing the Commission's decision and the subsequent writ of execution. Lopez-Jison contends that the judgment and writ of execution have been fully satisfied by her payments. The Social Security Commission, in lieu of a formal comment, filed a manifestation stating that due to Executive Order No. 28, which condones the 3% penalty on delinquent employers, the SSS is no longer pursuing its claim, as indicated by zero balances on their statements.
Issue(s)
Whether the petition for prohibition to cease and desist from enforcing the judgment of the Social Security Commission should be granted, considering the subsequent condonation of penalties. Whether the judgment against the petitioner and the writ of execution issued pursuant thereto had been effectively satisfied due to the Social Security Commission no longer pursuing its claim.
Ruling
The petition is dismissed. The Social Security Commission, in its manifestation, stated that in view of Executive Order No. 28, which provides for the condonation of the 3% penalty imposed on delinquent employers, the SSS is no longer pursuing its claim against the petitioner. Annexes submitted showed a zero balance.
Ratio Decidendi
On the issue of whether the petition for prohibition should be granted: The Court dismissed the petition for prohibition because the Social Security Commission (SSC) was no longer pursuing its claim against the petitioner due to Executive Order No. 28, which condoned the 3% penalty imposed on delinquent employers. This rendered the petitioner's plea for prohibition moot and academic. On the issue of whether the judgment had been effectively satisfied: The respondent submitted evidence showing a zero balance, corroborating the SSC's manifestation that the claim was no longer being pursued and that the petitioner's liabilities concerning penalties had been effectively waived or condoned. The petitioner's argument that the judgment had been fully satisfied was rendered moot by the SSC's decision not to collect the penalty. Therefore, the Court found no further need to compel the respondents to cease and desist from enforcing a judgment that was no longer being actively pursued.
Main Doctrine
A petition for prohibition to cease and desist from enforcing a judgment is dismissed when the respondent commission manifests that it is no longer pursuing its claim due to a condonation of penalties, and records show a zero balance.