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    Jurisprudence On Finality of Administrative Action Philippine American Life Insurance Co. vs. Social Security System GR No. L-20383 May 24, 1967

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    Reynier Molintas Clemens
    1) The trial court ruled that Philippine American Life Insurance Company's (PhilAm) agents were not employees of PhilAm and not subject to compulsory coverage by the Social Security System (SSS). However, the Supreme Court overturned this ruling. 2) The Supreme Court held that the trial court did not have jurisdiction to issue a writ of prohibition against the SSS Commission since the Commission is not inferior to the trial court given its quasi-judicial functions. 3) The Supreme Court also held that PhilAm did not have a valid cause of action yet since it did not first exhaust its administrative remedies by appealing the SSS' decision to the Commission, as required by law.

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    Jurisprudence On Finality of Administrative Action Philippine American Life Insurance Co. vs. Social Security System GR No. L-20383 May 24, 1967

    Uploaded by

    Reynier Molintas Clemens
    35 views1 page
    1) The trial court ruled that Philippine American Life Insurance Company's (PhilAm) agents were not employees of PhilAm and not subject to compulsory coverage by the Social Security System (SSS). However, the Supreme Court overturned this ruling. 2) The Supreme Court held that the trial court did not have jurisdiction to issue a writ of prohibition against the SSS Commission since the Commission is not inferior to the trial court given its quasi-judicial functions. 3) The Supreme Court also held that PhilAm did not have a valid cause of action yet since it did not first exhaust its administrative remedies by appealing the SSS' decision to the Commission, as required by law.

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    1) The trial court ruled that Philippine American Life Insurance Company's (PhilAm) agents were not employees of PhilAm and not subject to compulsory coverage by the Social Security System (SSS). However, the Supreme Court overturned this ruling. 2) The Supreme Court held that the trial court did not have jurisdiction to issue a writ of prohibition against the SSS Commission since the Commission is not inferior to the trial court given its quasi-judicial functions. 3) The Supreme Court also held that PhilAm did not have a valid cause of action yet since it did not first exhaust its administrative remedies by appealing the SSS' decision to the Commission, as required by law.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    35 views1 page

    Jurisprudence On Finality of Administrative Action Philippine American Life Insurance Co. vs. Social Security System GR No. L-20383 May 24, 1967

    Uploaded by

    Reynier Molintas Clemens
    1) The trial court ruled that Philippine American Life Insurance Company's (PhilAm) agents were not employees of PhilAm and not subject to compulsory coverage by the Social Security System (SSS). However, the Supreme Court overturned this ruling. 2) The Supreme Court held that the trial court did not have jurisdiction to issue a writ of prohibition against the SSS Commission since the Commission is not inferior to the trial court given its quasi-judicial functions. 3) The Supreme Court also held that PhilAm did not have a valid cause of action yet since it did not first exhaust its administrative remedies by appealing the SSS' decision to the Commission, as required by law.

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    © All Rights Reserved
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    JURISPRUDENCE ON FINALITY OF ADMINISTRATIVE ACTION

    Philippine American Life Insurance Co. vs. Social Security System


    GR No. L-20383
    May 24, 1967

    FACTS: On November 6, 1960, the Social Security System — hereinafter referred to as the System — issued, with the approval of
    the Chairman of the Social Security Commission — hereinafter referred to as the Commission — Circular No. 34 (Exhibit A),
    requiring all insurance firms to submit immediately the names of their agents, solicitors or underwriters, who, pursuant to the Social
    Security Act 1 — hereinafter referred to as the Act — are deemed employees of said firms which are then subject to compulsory
    coverage of the System. They are instructed to pay the corresponding premiums, based on the actual commissions received by
    each agent during each month.

    The System sent to the Philippine American Life Insurance Company the communication dated February 11, 1961, enclosing the
    SSS Form R-1-A.1 and advising PhilAm, that based on Circular No. 34, the insurance agents are considered its employees and are
    subject to compulsory coverage under said Act, thereby urging them to accomplish said SSS Form (for the purpose of supplying the
    necessary data concerning said agents, solicitors and underwriters). Such document was to submitted within ten (10) days, to avoid
    the penalties provided for by law.

    Instead of complying with this request, on May 30, 1961, PhilAm commenced, in the Court of First Instance of Manila, the present
    action, for prohibition with preliminary injunction against the Commission — to restrain the latter from compelling them to remit
    contributions to the administrative branch of the System, as an incident of the alleged inclusion of PhilAm’s agents, solicitors or
    underwriters in the compulsory coverage of the System, and from prosecuting them and its officers for their refusal to make the
    aforementioned contributions — upon the theory that said agents of the PhilAm are not employees.

    The trial court ruled that holding that Philam’s agents, solicitors or under writers are not employees said insurance agents, solicitors
    or underwriters do not fall under the compulsory coverage of the Social Security System; The court commanded the defendant
    Social Security Commission to desist absolutely from taking criminal action against PhilAm Life’s key officers.

    ISSUES :

    1) Whether or not the trial court had jurisdiction to hear and decide this case; and
    2) Whether plaintiff has a cause of action against the Commission.

    RULING :

    1. No. The appeal taken by the Commission is well-founded for the present action is one for a writ of prohibition, which may be
    issued only by a superior court to an inferior court, corporation, board or person, to prevent the latter from usurping or
    exercising a jurisdiction or power it does not have (3 Moran on Rules of Court, 1963 ed., p. 157). Section 5 (a) of the Act
    acknowledges in the Commission the power to determine and settle claims, which partakes of a quasi-judicial function, in the
    exercise of which, the Commission is not inferior to courts of first instance, in much the same way as the Public Service
    Commission, as a board performing quasi-judicial functions, is not inferior to said courts. The quasi-judicial nature of the
    functions of the Commission is emphasized by its authority, expressly granted by said Section 5 (a), to promulgate rules and
    regulations governing "the filing, determination and settlement of claims." Hence, the lower court had no jurisdiction to issue
    the writ of prohibition prayed for.

    2. NO. pursuant to Section 5 (b) of said Act, the judicial review of "any decision of the Commission . . . shall be permitted only
    after any party claiming to be aggrieved thereby has exhausted his remedies before the Commission." PhilAm Life has not
    exhausted its remedies before the Commission. The Commission has not even been given a chance to render a decision on
    the issue raised by Philam because the latter has not appealed to the Commission from the action taken by the System in
    insisting upon the enforcement of Circular No. 34.

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