Velasco v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents, drivers led by Herminio Rivera, filed a petition with the Social Security Commission (SSC) against their employer, spouses Salvador and Soledad Velasco, who owned and operated passenger jeepneys. The drivers alleged that despite deductions for Social Security System (SSS) contributions from their daily wages, the Velasco spouses only reported them for coverage after a complaint was lodged with the SSS. The Velasco spouses denied these allegations, claiming some drivers had executed quitclaims, that the relationship was one of lessor-lessee, and that contributions were indeed remitted. Procedural History: The SSC issued a resolution on September 6, 1995, ordering Salvador Velasco to remit P774,149.86 in contributions and penalties. A motion for reconsideration was denied on May 8, 1996. Following Salvador Velasco's death on May 27, 1996, Soledad Velasco filed a petition for review with the Court of Appeals (CA) on June 28, 1996. The CA dismissed this petition on February 14, 1997, for failure to submit certified true copies of the SSC resolutions, and subsequently denied the motion for reconsideration on July 31, 1997. The Petition: Petitioner Soledad E. Velasco filed a petition for certiorari with the Supreme Court, arguing that the CA committed grave abuse of discretion in dismissing her petition for review. She contended that the CA erroneously applied Section 3-b, Rule 6 of the Revised Internal Rules of the Court of Appeals (RIRCA) instead of Section 6 of the same rule, as amended by Supreme Court Circular No. 1-91, or Administrative Circular No. 1-95. Petitioner asserted that she had attached duplicate original copies of the SSC resolutions, which, upon closer inspection and considering Supreme Court Administrative Circular No. 3-96, qualified as compliant documents, thus the CA should have given due course to her petition.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for review for failure to submit certified true copies of the assailed resolutions. Whether the obligation to remit SS contributions was extinguished upon the death of Salvador Velasco. Whether the SSC's order for remittance of P774,149.86 was sufficiently substantiated. Whether the SSC gave undue weight to private respondents' exhibits not formally offered in evidence.
Ruling
The petition is GRANTED. The Resolution of the Court of Appeals dated February 14, 1997, dismissing the petition for review, and its Resolution dated July 31, 1997, denying the motion for reconsideration, are SET ASIDE. The Court of Appeals is ORDERED to GIVE DUE COURSE to the petition for review. The records are REMANDED to the Court of Appeals for further proceedings.
Ratio Decidendi
On the issue of grave abuse of discretion in dismissing the petition for review: The Supreme Court held that the Court of Appeals committed grave abuse of discretion. The petitioner argued that Section 6 of Rule 6 of the RIRCA, as amended by Supreme Court Circular No. 1-91, was applicable, which allowed for a duplicate original copy. However, the Court clarified that at the time of filing, Administrative Circular No. 1-95 was in effect, which also required a "clearly legible duplicate original or a certified true copy." Crucially, Administrative Circular No. 3-96, effective June 1, 1996, defined "duplicate original copy" to include copies bearing the dry seal of the issuing entity. The Court found that the documents attached by the petitioner, though appearing photostatic, bore the dry seal of the SSC, thus qualifying as duplicate original copies under the applicable circular. Therefore, there was compliance with the rules, and the CA's dismissal was erroneous. The SSS's failure to refute the petitioner's claim in its Comment further supported this conclusion, constituting an implied admission. On the issue of extinguishment of obligation upon death: This issue was not directly ruled upon by the Supreme Court as the case was remanded to the Court of Appeals for further proceedings. The Court's primary focus was on the procedural defect raised by the petitioner regarding the dismissal of her appeal. On the issue of substantiation of the SSC's remittance order: This issue was also not directly ruled upon by the Supreme Court. The Court's decision centered on the procedural aspect of the CA's dismissal. The substantive merits of the SSC's computation and order were to be determined by the CA upon giving due course to the petition. On the issue of admitting unoffered exhibits: Similar to the previous substantive issues, the Supreme Court did not delve into the merits of whether the SSC gave undue weight to unoffered exhibits. The remand to the CA implies that these substantive matters, including the evidentiary issues, are to be addressed by the appellate court in its review of the case.
Main Doctrine
The Court of Appeals committed grave abuse of discretion in dismissing a petition for review solely on the ground of failure to submit certified true copies of the assailed resolutions when the petitioner had submitted duplicate original copies, which, under Supreme Court Administrative Circular No. 3-96, qualify as sufficient compliance with the rules.