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Kilusang Mayo Uno Case Notes
Kilusang Mayo Uno Case Notes
NOTES
Baltazar, Guillan Audrey M. | 1LM-3
💡 Case Presentation
This case of Kilusang Mayo Uno v. Hon. Aquino III resolves a Petition for Certiorari
and Prohibition, praying that a temporary restraining order and/or writ of preliminary
injunction be issued to annul the Social Security System premium hike.
The Social Security Commission issued Resolution No. 262-s. 2013, which provided
an increase in: (1) the Social Security System members' contribution rate from
10.4% to 11%; and (2) the maximum monthly salary credit from ₱15,000.00 to
₱16,000.00.
However, Kilusang Mayo Uno, et al. filed this Petition for Certiorar and Prohibition,
questioning the validity of the assailed issuances.
Petitioners claim that the assailed issuances were issued per an unlawful delegation
of power to respondent Social Security Commission based on Republic Act No.
8282, or the Social Security Act, and that the delegation of the power had no
adequate legal guidelines to map out the boundaries of the delegate's authority.
Petitioners also pray that a temporary restraining order and/or writ of preliminary
injunction be issued to stop the implementation of the increase in contributions.
💡 Ruling
Petitioners have failed to show that there was an invasion of a material and
substantial right, or that they were entitled to such a right. Moreover, they failed to
WHEREFORE, the Petition is DENIED for lack of merit. Resolution Nos. 262-s. 2013
and 711-s. 2013 issued by the Social Security Commission, as well as Circular No.
2013-010 issued by the Social Security System, are valid. The prayer for the issuance
of a temporary restraining order and/or writ of preliminary injunction is also DENIED.
(Sections 4 and 5 of the Social Security Act are clear that the Social Security
Commission has jurisdiction over any dispute arising from the law regarding
coverage, benefits, contributions, and penalties. The law further provides that the
aggrieved party must first exhaust all administrative remedies available before
seeking review from the courts).
- jurisdiction is determined by laws enacted by Congress. The doctrine of
exhaustion of administrative remedies ensures that this legislative power is
respected by courts. Courts cannot ignore Congress' determination that the Social
Security Commission is the entity with jurisdiction over any dispute arising from
the Social Security Act with respect to coverage, benefits, contributions, and
penalties.
💡 Fact Bank
It would, thus, be premature for courts to take cognizance of the case prior to the
exhaustion of remedies, not to mention it would violate the principle of separation of
powers. Thus, in Rule 65 petitions, it is required that no other plain, speedy, or adequate
remedy is available to the party.
Going into the validity of respondents' actions, petitioners must show that the
assailed issuances were made without any reference to any law, or that
respondents knowingly issued resolutions in excess of the authority granted to them
under the Social Security Act to constitute grave abuse of discretion.
Here, respondents were only complying with their duties under the Social Security
Act when they issued the assailed issuances. There is no showing that respondents
went beyond the powers under the law that amounts to lack of or in excess of their
jurisdiction. Petitioners' claims are unsubstantiated and, as such, merit no finding of
grave abuse of discretion.