Asiatic Development Corporation v. Brogada
REITERATIONFacts
The Antecedents: Respondents Wellington and Flordeliza Brogada alleged that their son, Fermin B. Brogada, was employed by petitioner Asiatic Development Corporation from July 1994 until his death on November 14, 1996. Fermin was allegedly employed as a survey aide under Engr. Bienvenido Orense, petitioner’s geodetic engineer, and was working on a project for one of petitioner’s clients when he was shot and killed. Procedural History: Respondents filed a petition with the Social Security Commission (SSC) for social security coverage and payment of contributions, seeking benefits from Fermin's death. Petitioner denied liability, asserting that Fermin was an employee of Engr. Orense, not of petitioner, and thus petitioner was not obligated to report him for social security coverage. The SSC ruled in favor of respondents, finding Fermin to be an employee of petitioner from July 1994 to November 14, 1996, and ordered petitioner to pay unpaid social security contributions, penalties, and damages for failure to report Fermin for coverage. The Court of Appeals (CA) affirmed the SSC resolution. Petitioner appealed to the Supreme Court. The Petition: Petitioner insisted before the Supreme Court that Fermin was not its employee.
Issue(s)
Whether the Supreme Court can review the factual finding of an employer-employee relationship made by the Social Security Commission and affirmed by the Court of Appeals. Whether Fermin B. Brogada was an employee of Asiatic Development Corporation for the period of July 1994 to November 14, 1996.
Ruling
The petition is denied. The Supreme Court affirmed the decision of the Court of Appeals which upheld the resolution of the Social Security Commission finding an employer-employee relationship between petitioner Asiatic Development Corporation and the late Fermin B. Brogada, and holding petitioner liable for unpaid social security contributions, penalties, and damages.
Ratio Decidendi
On the issue of reviewing factual findings: The issue of whether an employer-employee relationship exists is a question of fact. Under Rule 45 of the Rules of Court, petitions for review on certiorari are limited to questions of law. The Supreme Court generally accords respect and finality to the factual findings of quasi-judicial bodies, such as the Social Security Commission, when these findings are adopted and confirmed by the Court of Appeals and are supported by substantial evidence. The Court noted that no exceptions to this rule were applicable in the present case. Therefore, the Supreme Court could not disturb the factual determination that Fermin was an employee of petitioner. On the existence of an employer-employee relationship: Both the Social Security Commission and the Court of Appeals concurrently found that Fermin B. Brogada was an employee of petitioner Asiatic Development Corporation. This factual determination was based on substantial evidence presented before the SSC. Petitioner's arguments to the contrary were merely a reiteration of claims previously made and rejected by the lower bodies. As the factual findings were supported by substantial evidence and affirmed by the CA, the Supreme Court found no compelling reason to reverse these conclusions. Consequently, petitioner was deemed liable for the unpaid social security contributions and associated penalties and damages.
Main Doctrine
Factual findings of quasi-judicial bodies like the Social Security Commission, when adopted and confirmed by the Court of Appeals and supported by substantial evidence, are accorded respect and finality by the Supreme Court, barring exceptions not present in this case.