Social Security System v. Court of Appeals
REITERATIONFacts
The Antecedents: Felicisima Orcino filed a petition with the Social Security System (SSS) against architect Manuel G. Ramos, alleging that Ramos, as Emeterio Orcino's employer, failed to register Emeterio with the SSS. Felicisima sought payment of death benefits equivalent to what would have been payable had Emeterio been registered. Emeterio, who worked as a laborer and later foreman, died on May 29, 1971, from a work-induced ailment. Felicisima received P4,192.00 as death compensation from Ramos and Ms. de Jesus (owner of the construction project) and P3,600.00 for the dismissal of her SSS claim, executing documents acknowledging these as full payment for claims under the Workmen's Compensation Act and dismissal of the SSS case. Procedural History: Ramos denied being a builder or contractor, stating his profession was solely as an architect, and his involvement in construction projects was limited to supervision. He claimed Emeterio worked for him intermittently for a year and that the payments made were out of charity, not an acknowledgment of employment. The SSS intervened, noting Emeterio was not listed in Ramos's SSS registration and that Ramos failed to submit required reports. The SSS ruled in favor of Felicisima, holding Ramos liable for death benefits and back contributions, but allowing deduction for the P3,600.00 paid. On appeal, the Court of Appeals reversed the SSS ruling, finding insufficient evidence to establish an employer-employee relationship between Ramos and Emeterio, and concluding that Ms. de Jesus was Emeterio's actual employer. The SSS appealed to the Supreme Court. The Petition: The SSS assailed the Court of Appeals' conclusion that no employer-employee relationship existed between Ramos and Emeterio, and that Ms. de Jesus was the employer.
Issue(s)
Whether the Court of Appeals erred in concluding that no employer-employee relationship existed between Manuel G. Ramos and Emeterio Orcino; specifically, whether the factual findings of the Court of Appeals regarding the lack of evidence of an employer-employee relationship were erroneous. Whether the payments made by Manuel G. Ramos to Felicisima Orcino constituted an admission of employment, and whether such payments established a legal duty rather than being acts of charity.
Ruling
The petition for review on certiorari is denied, and the judgment of the Court of Appeals is affirmed. The Supreme Court held that it will not review factual findings of the Court of Appeals, and the evidence did not sufficiently establish an employer-employee relationship between Ramos and the deceased. The payments made by Ramos were considered acts of pity and charity, not an acknowledgment of legal liability.
Ratio Decidendi
On the issue of employer-employee relationship and the Court of Appeals' factual findings: The Supreme Court reiterated its long-standing policy of not reviewing factual findings of the Court of Appeals, as this is not ordinarily its function. The Court emphasized that a petition for review on certiorari must raise only questions of law. In this case, the Court of Appeals, after assessing the evidence, concluded that there was no employer-employee relationship between Ramos and Emeterio Galang. The Appellate Tribunal found the evidence presented by the SSS inadequate to establish such a relationship, deeming portions of Felicisima Orcino's testimony as hearsay and other parts as inaccurate when compared to Ramos's proofs. The Court of Appeals also found that Ramos had never hired any employees except for one year, and those he recruited, including Emeterio, were employed by the structure owners who paid their wages. Ramos, in his professional capacity as an architect, had no financial outlay for hiring laborers or employees during the material period. Therefore, based on these factual conclusions of the Court of Appeals, which were not shown to be unsupported by evidence or erroneous, Ramos could not be held liable. On whether the payments made by Ramos constituted an admission of employment: The Supreme Court found that the two documents evidencing payments to Felicisima Orcino did not constitute persuasive proof of an employment relationship. These documents were signed only by Ms. Orcino and her lawyer, not by Ramos or Ms. de Jesus. Consequently, they could not be deemed admissions by either Ramos or Ms. de Jesus. Furthermore, the Court of Appeals found, and the Supreme Court found no error in this finding, that the payments were made out of considerations of pity and charity, and not from a consciousness of a legal duty to do so. The Court cited Catalla v. Tayabas Lumber Co., stating that cases should be decided based on proven facts and applicable law, not solely from a sympathetic viewpoint, and where no contractual or juridical relation is proven, a claim for compensation should be denied.
Main Doctrine
The Supreme Court will not review factual findings of the Court of Appeals, especially when the evidence does not sufficiently establish an employer-employee relationship, and payments made by an alleged employer were out of pity and charity, not from a consciousness of legal duty.