Case Title H. Villarica Pawnhop, Inc. v. Social Security Commission G.R. No.

228087, January 24, 2018 [J. Gesmundo, Third Division].

Ponente GESMUNDO, J.
Keywords/Terms
Social Security System (SSS)

Provision/Doctrine A. SSS Law (RA 8282)

1. Dependents and beneficiaries
2. Benefits
B. GSIS Law (RA 8291)
1. Coverage and exclusions
2. Dependents and beneficiaries
3. Benefits
C. Disability and death benefits

Facts The petitioners resolved their overdue contributions and accumulated

penalties with the Social Security System (SSS) in 2009. Subsequently,
Congress enacted a law effective in 2010, permitting delinquent employers
to settle their outstanding contributions without incurring penalties. Despite
the enactment of this law, the petitioners, who had settled their obligations
before its implementation, sought reimbursement of accrued penalties
through two letters to the SSS. However, the SSS rejected their requests.
The petitioners then pursued reimbursement through the Social Security
Commission (SSC), but their claim was denied due to a perceived lack of
merit. The Court of Appeals (CA) also dismissed their petition for appeal,
along with a subsequent motion for reconsideration. As a result, the petition
at hand was filed.
Issue WON the Petitoners are entitled for the reimbursement of the accrued
penalties
Ruling The court held that under the Social Security Act of 2018 (R.A. No. 9903),
employers who were delinquent in remitting contributions to the Social
Security System (SSS) could avail of a condonation program. This program
allowed delinquent employers to remit contributions or propose installment
payments within six months from the act's effectivity. Upon approval and
full payment, pending cases against the employer would be withdrawn.
However, if the employer failed to fulfill the requirements within the
specified period, penalties would be reimposed.

The court emphasized that there was no provision in the law benefiting
employers who settled their delinquent contributions before the law's
effective date. Therefore, employers who had already settled their
contributions before the law's enactment were not entitled to
reimbursement under the mentioned law.

WHEREFORE, the petition is DENIED. The February 26, 2016 Decision

and November 2, 2016Resolution of the Court of Appeals in CA G.R. SP
No. 140916 are AFFIRMED