Ramos, Dianne Nicole L.

Exceptions to the SSS Law

Agrarian Law and Social Legislation / 2C SSS Law
Case Digest Roman Catholic Archbishop of Manila v. SSC
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ROMAN CATHOLIC ARCHBISHOP OF MANILA v. SOCIAL SECURITY COMMISSION

G.R. No. L-15045, 20 January 1961

FACTS:

Petitioners sought to have all religious and charitable institutions and organizations be
exempted from compulsory coverage of RA No. 1161 because it is a labor law. According to
petitioners, labor laws do not cover religious and charitable institutions but is limited to business
and activities organized for profit. The respondents denied the request. The petitioners sought
for reconsideration but were once again denied, hence this appeal.

The petitioners argued that the term “employer”, as used in the SSS law, would be limited to
those who carry on undertakings or activities which have the element of profit or gain, or which
are pursued for profit or gain. This is following the principle of ejusdem generis.

Furthermore, the petitioners cited Senate discussions where it was stated that the SSS law is
intended to cover employment for profit or gain. They also cited jurisprudence, which states that
labor laws apply only to industry and occupation for purposes of profit of gain.

Lastly, petitioners argue that to include religious and charitable institutions would go against the
constitutional prohibition of applying public funds in support of priests. And that it would go
against their right to disseminate religious information.

ISSUE:

Whether or not religious institutions should be exempted from the SSS law.

RULING:

No. The coverage of the SSS law is predicated on the existence of the employer-employee
relationship of more or less permanent nature and extends to employment of all kinds except
those expressly included.

As to the petitioner’s argument of following the principle of ejusdem generis when interpreting
the meaning of “employer”, the Court stated that such principle only applied when there is
uncertainty. But in the case at bar, there is already an exception, which does not include
religious and charitable institutions. This shows that the legislature intended these to be covered
by the law.

The Senate discussions cited by the petitioner do state who are included in under the SSS law.
But this does not exclude everything else that was not mentioned. Also, the laws in the
jurisprudence cited by the petitioners do, in fact, expressly limit the application of labor laws to
those mentioned. However, the SSS law is enacted in a legitimate exercise of police power in
accord with the constitutional provision to promote social justice.

Lastly, the Court stated that the funds of the SSS are private. They belong to the members and
are merely held in trust by the government. Hence, such payment, when made to a priest, is
made to him because he is an employee, not because he is a priest. Also, what is asked of the

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 Ramos, Dianne Nicole L. Exceptions to the SSS Law
Agrarian Law and Social Legislation / 2C SSS Law
Case Digest Roman Catholic Archbishop of Manila v. SSC
---------------------------------------------------------------------------------------------------------------------------

petitioner is only to make monthly contributions, these are not in the nature of taxes, they are
merely to promote social justice.

DISPOSITION:

IN VIEW OF THE FOREGOING, Resolutions Nos.572 kind 767, series of 1958, of the Social
Security Commission are hereby affirmed. So ordered with costs against appellant.