CASE DIGEST

Written By: SULLANO, Gavriil

Case Name: In re Petition for Exemption from Coverage by the SSS,
Roman Catholic Bishop of Manila vs. SSC
Doctrine:

Coverage of SSS Law is predicated upon existence of an employeremployee relationship. It extend to employment of all kind, except those
expressly excluded (ie government). The definition provided by law shows
the legislative intent to include religious and charitable institutions, despite
not operating for profit
Facts:
RCB seeking exemption from SSS Law coverage, citing it is a religious
institution
o RCB: Only businesses for profit are subject to SSS
o RCB employees include priests (Inferred fact; related to last bullet
discussed under Ruling)

Issue:
W/N religious and charitable institutions fall under the coverage of the SSS
Law? - YES
Ruling:

Section 9, SSS Law: Compulsory

o All employees 16-60 years old
o At least 6 months in service of employer, member of the system
o Employers are compelled to be members of the system if they have
been in operation for at least 2 years
Section 8: Definitions
o Employer: Any person, natural or juridical, domestic or foreign...
who carries on business in the PHL and uses the service of another
person who is under his orders... Except the government
o Employee: Any person who performs services for an employer, and
who receives compensation
Coverage of SSS Law is predicated upon existence of an employeremployee relationship. It extend to employment of all kind, except those
expressly excluded (ie government)
The definition provided by law shows the legislative intent to include
religious and charitable institutions, despite not operating for profit
o For profit is not a requirement to be an employer within coverage
SSS Law is a legitimate exercise of police power

"Promotion of social justice to insure the well being and economic

security of all"
o Compatible with policy of Church to help the poor
SSS Law funds are NOT public funds
o Constitution prohibits priests from receiving public funds
o Priests can be under SSS coverage because they are not receiving
public funds; they are receiving funds belonging to members and
held in trust by the Government
o